Legal

Privacy Policy

Last updated:

8 November 2026

This Privacy Policy explains how StemNotes Ltd (“StemNotes”, “we”, “us”, or “our”) collects, uses, and protects your personal data when you use the StemNotes mobile and watch applications and related services (the “App”). We are the data controller for your personal data.

If you have any questions, contact us at support@stemnotes.io.

1. Who we are

StemNotes Ltd 5 Ducket Close, Richmond, North Yorkshire, DL10 5QD Contact: support@stemnotes.io

We are based in England, United Kingdom and comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (and, where applicable, the EU GDPR).

2. The data we collect

Account and identity data

Email address

First and last name

Gender (optional)

Date of birth

Profile photo (optional, if you upload one)

Authentication identifiers from Apple or Google if you sign in with those providers

Fitness and training data you provide

Critical Power (CP)/FTP, training status, maximum carbohydrate intake, feed interval, power-mode and fuelling preferences

Planned and completed sessions, workout structure, and the fuelling plans we generate for you

Menstrual cycle data (optional)

If your biological sex is set to female, the App asks whether you feel more fatigued during part of your menstrual cycle. If you choose to use this feature, you enter how strong that fatigue is, when it happens around your period, your usual cycle and period length, and the dates your periods start. This data stays on your device. The App uses it to work out which days your fuelling plans should carry more carbohydrate.

If you have connected TrainingPeaks, or paired our Karoo app from your phone, the App sends our servers one thing derived from this data: a list of the next 21 days on which your fuelling plans are raised, and by how much (for example, “8 October: one step”). We use it only so our Karoo app can show you the same fuelling plans as your phone. We never receive your period dates, your cycle or period length, or your answers. Because the list can indicate when your period is expected, we treat it as health data.

Apple Health (Apple Watch app)

If you turn on Record as workout in our Apple Watch app, the watch uses Apple HealthKit to record your ride as a cycling workout. It reads your heart rate and active energy during the ride and saves the finished workout to Apple Health. This data stays on your devices and in Apple Health: we never receive your heart rate or your workouts, and we don’t use HealthKit data for advertising or share it with anyone. You can turn recording off at any time in the watch app, or remove StemNotes’ access in the Health app.

Data from services you connect

If you connect TrainingPeaks or intervals.icu, we access your planned and completed workouts, workout structure, power/intensity data and related metrics via those services’ authorised APIs, solely to generate your fuelling recommendations.

If you turn on calendar notes, the App also adds a “StemNotes Fuel Plan” note to your TrainingPeaks or intervals.icu calendar for each planned session, and updates it with what you ate after the ride. It never changes your own workouts. Turn the notes off in Settings and the App removes the notes it added.

Garmin Connect

If you connect Garmin Connect, Garmin sends our servers each activity you record from then on. For cycling activities we keep the ride’s name, type, start time and duration, the device you recorded it on, its average power and the power recorded during the ride. We discard everything else Garmin sends, and we don’t keep non-cycling activities. We use these rides only to match each one to your planned session and work out the carbohydrate you should have eaten for the ride you actually did. We don’t receive rides recorded before you connected. We never sell Garmin data or share it with anyone else, no AI system processes it, and we don’t use it to train or improve AI models.

Workout descriptions

On a paid plan, when you describe a workout in Add Workout, we send the text you typed and your Critical Power to Anthropic, whose AI model turns it into a structured workout. We send nothing else with it: no name, email or other training data. Anthropic doesn’t use this data to train its models. We keep a count of the workout credits you have used this month and any you have bought.

Fuelling plans on your watch or Garmin Edge

If you link our Apple Watch app or Garmin Edge field, the App sends our servers your upcoming fuelling plans (session names, timings and carbohydrate amounts) so the device can download them, including when your phone isn’t nearby.

Subscription and purchase data

Records of your subscription status and entitlements, and of any workout-credit packs you buy (the App Store transaction ID and the number of credits added). Payments are processed by Apple through the App Store, or by Google through Google Play on Android. We never receive or store your payment card details.

Access codes

If you enter an access code, we check your account email against the list of riders that code covers, and record that you redeemed it, when your free access started and when it ends.

Device and technical data

Basic technical information necessary to operate the App and deliver notifications (e.g. device/OS type, app version, and a push notification identifier where applicable). If you use our Karoo app, Garmin Edge field or Apple Watch app, we also record against your account which of them you have paired and when each last downloaded a plan, so we can support them.

Fuel cards you share

When you share a fuel card from the App (to an Instagram or Facebook Story, by saving or copying it, or to another app), we record your name and account email, the ride’s title, date, duration and intensity, the planned and eaten carbohydrate shown on the card, which card you shared and where you sent it. We do not receive the image, and we never include menstrual cycle data in these records.

Trial emails

If your account is new, the App reports your plan to our servers for about your first five weeks, or until any offer we email you ends: whether you are on a free plan, a trial or a paid plan, when it ends, which subscription it is, its price, and whether you use iOS or Android. We store this with your name, account email and the date you joined, so that we only send emails that fit your plan and can apply any offer we email you. Accounts more than six days old when the App first reports aren’t included, and we store nothing for them.

If Marketing emails is on, the App also sends a summary of your recent rides. For each ride it sends the date, the planned and eaten carbohydrate, the duration and whether you completed it, covering the last 21 days and up to 40 rides. We never receive ride titles or menstrual cycle data in these summaries. We use them to show you your own numbers in emails during your first weeks. If Marketing emails is off, the App sends no rides and we don’t send you these emails.

Website visits

When you visit stemnotes.io we ask whether we can count your visit. If you say yes, we count which pages you view, where you came from (such as a search engine, social app or campaign link), your country, your type of device and which links and buttons you use. We don’t use cookies for this. To tell visits apart, we combine your IP address and browser details with a random value we replace each day and turn them into a one-way code. We delete the code and the random value within 25 hours, we never store your IP address, and what we keep is daily totals that don’t identify you. We do this to see which pages and campaigns work, based on your consent. If you say no, we count nothing.

Turn off this counting on this device. We remember your answer with one setting in your browser. If your browser sends a Global Privacy Control or Do Not Track signal, we treat that as no. Framer, which hosts our website, records its own page statistics for us, and this choice doesn’t affect those.

We do not use third-party advertising or third-party usage-analytics SDKs in the App.

3. How we collect it

Directly from you — when you create an account, complete onboarding, enter your details, or use the App.

From sign-in providers — if you choose Sign in with Apple or Google, we receive your email and a provider identifier (Apple may provide a private relay email if you choose “Hide My Email”).

From connected services — TrainingPeaks, intervals.icu and Garmin Connect, only after you explicitly authorise the connection.

4. How and why we use your data (and our lawful bases)

Purpose

Data used

Lawful basis (UK GDPR)

Create and manage your account

Email, name, authentication IDs

Performance of a contract

Generate personalised fuelling recommendations

Fitness/training data, connected-service data (including rides from Garmin Connect)

Performance of a contract

Adjust your fuelling plans to your menstrual cycle, and sync the adjusted days to your Karoo

Menstrual cycle data; the list of adjusted days

Explicit consent (UK GDPR Article 9(2)(a)), given when you choose to use the feature

Provide and sync sessions across your devices/watch

Sessions, plans, device data

Performance of a contract

Manage subscriptions and entitlements

Subscription status

Performance of a contract

Apply access codes and workout credits

Email, code redemptions, credit balance and credit purchases

Performance of a contract

Turn a typed workout description into a structured workout (paid plans)

The description you type, Critical Power

Performance of a contract

Deliver your fuelling plans to your watch or Garmin Edge, and support our device apps

Upcoming fuelling plans; which device apps you have paired and when they last downloaded a plan

Performance of a contract / legitimate interests

Send you service and onboarding communications

Email, first name, date of birth

Legitimate interests / consent

Send trial emails showing your own ride numbers and, where you qualify, an offer

Email, first name, plan status, ride summaries

Consent to marketing emails; legitimate interests for including your own ride numbers

Check your plan so that emails fit it, and apply offers

Plan status, platform, email, join date

Legitimate interests

Understand how riders use fuel-card sharing, to improve it

Share records: name, email, the ride details on the card, card and destination

Legitimate interests

Improve and secure the App

Technical data

Legitimate interests

Comply with legal obligations

As required

Legal obligation

Where we rely on consent, you may withdraw it at any time (see Section 8).

5. Sharing your data — our processors and third parties

We share personal data only as necessary to run the service. We do not sell your personal data.

Google / Firebase (Google Ireland Ltd / Google LLC) — account authentication and secure storage of your account and profile data.

Apple (Apple Inc. / Apple Distribution International) — Sign in with Apple, App Store subscriptions and in-app purchases.

Google Play (Google Ireland Ltd / Google LLC) — subscription processing on Android.

Google Sign-In (Google) — if you sign in with Google.

TrainingPeaks (Peaksware, LLC) and intervals.icu — connected only at your request, to import your training data.

Garmin (Garmin International, Inc.) — connected only at your request; Garmin sends us your recorded activities as described in Section 2.

Make.com (Celonis / operated by Make) — when you complete signup, we send your email, first name, last name, gender and date of birth to our onboarding/CRM workflow to set up and communicate with you about your account.

Anthropic, PBC — turns the workout descriptions you type into structured workouts, on paid plans only, as described in Section 2.

Vercel Inc. — hosting for our backend service, which proxies requests to the above APIs.

Upstash, Inc. — database for the fuelling settings we sync to our Karoo app, including the list of cycle-adjusted days described in Section 2, the records of fuel cards you share, your Garmin Connect connection and the rides Garmin sends us, the fuelling plans sent to your watch or Garmin Edge, your workout-credit balance and purchases, your access-code redemptions, and the plan status and ride summaries used for trial emails.

Amazon Web Services (Amazon SES, EU Stockholm region) — sends the trial emails and holds your email address and unsubscribe choice on our sending list.

EmailOctopus — our mailing list provider. Before sending a trial email we check you haven’t unsubscribed there, and we pass on any unsubscribes from the trial emails.

Some of these providers are located outside the UK/EEA. Where personal data is transferred internationally, we rely on appropriate safeguards such as the UK International Data Transfer Agreement/Addendum, EU Standard Contractual Clauses, or an adequacy decision.

6. How long we keep your data

We keep your personal data for as long as your account is active. If you delete your account (see Section 8) or it becomes inactive, we delete or anonymise your personal data within a reasonable period, except where we must retain certain records to meet legal, accounting or dispute-resolution obligations.

The fuelling settings we sync to our Karoo app, including the list of cycle-adjusted days, are replaced each time the App syncs and deleted automatically 120 days after the last sync. Menstrual cycle data on your device is deleted when you delete the App.

The fuelling plans sent to your watch or Garmin Edge are replaced on every sync and deleted automatically within 8 days.

Records of fuel cards you share are deleted automatically 90 days after each share. Only named StemNotes staff can see them, after signing in. Totals that do not identify you (for example, how many cards were shared in a month) are kept for up to 13 months.

Rides from Garmin Connect are deleted automatically 180 days after the ride. When you disconnect Garmin Connect, in the App or by removing StemNotes from your Garmin Connect account, we delete your connection and every ride we hold from it.

We delete your trial-email ride summaries once the last email that shows them has gone. That is around the end of your trial, about two weeks after you join if you aren’t on a trial, or after your first-week email if you are on a paid plan. The rest of the record, including your plan status, is deleted automatically 40 days after you join. We keep a list of which trial emails we sent you for 60 days after the last one, so you never get the same one twice. If you unsubscribe, we keep your email address and that choice on our sending list so we can honour it.

7. Security

We use technical and organisational measures to protect your data, including encrypted connections (HTTPS/TLS) and access controls. Your authentication tokens and session data are stored securely on your device. Garmin Connect access tokens are the exception: Garmin requires them to stay on our servers, so they never reach your device. No method of transmission or storage is completely secure, but we work to protect your information.

8. Your rights

Under UK/EU GDPR you have the right to: access your data; request rectification or erasure; restrict or object to processing; data portability; and to withdraw consent at any time.

You can delete your account and associated data directly in the App via Settings → Delete account.

You can withdraw your consent to cycle-based fuelling at any time in Settings → Menstrual cycle → Turn off cycle adjustments. Your plans stop being adjusted straight away, and the list of adjusted days on our servers is cleared the next time the App syncs.

You can disconnect Garmin Connect at any time in Settings → Integrations, or by removing StemNotes from the connected apps in your Garmin Connect account.

You can stop trial emails with the unsubscribe link in any of them, or by turning off Settings → Notifications → Marketing emails. Turning that setting off also stops the App sending rides, and removes the ones we hold the next time the App reports.

To exercise any other right, or to disconnect a linked service, contact us at support@stemnotes.io.

You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ico.org.uk) or your local supervisory authority.

9. Children

The App does not impose a minimum age. However, if you are under the age at which you can consent to the processing of personal data in your country (13 in the United Kingdom), a parent or guardian must review this policy and provide their consent on your behalf. If you believe a child has provided us with personal data without appropriate parental consent, please contact us and we will address it.

10. Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated version here and revise the “Last updated” date. Material changes will be notified in the App or by email where appropriate.

11. Contact us