Kyro Privacy Policy

1. Introduction

Kyro respects your privacy and is committed to protecting your personal information. This Privacy Policy explains what information we collect, how we use it, who we share it with, how we protect it, and your rights regarding your personal data.

Kyro is operated by KYRO APP LTD, a company registered in England and Wales under company number 17052490. Our registered office address is available on the public register at Companies House. For all privacy-related correspondence, please contact us at info@kyroapp.co.

Unless otherwise stated, Kyro acts as the data controller for personal information processed through the platform.

By using Kyro, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect

We collect information necessary to provide and improve the Kyro platform.

Account Information

When creating an account, we may collect:

• full name
• email address
• phone number
• date of birth
• password or login credentials
• home country
• gender (optional)

Booking & Usage Information

When using Kyro, we may collect:

• gym bookings
• booking history
• pass usage
• check-in confirmations
• customer support interactions

Emergency Contact Information

Users may provide an emergency contact name and emergency contact phone number. This information is used solely for safety and emergency-related purposes.

Optional Profile Information

Users may optionally choose to provide additional information, including profile photos, identity verification documents, accessibility requirements, or other profile-related information. Providing optional information is entirely voluntary.

Health or Accessibility Information (Special Category Data)

Some health and accessibility information may constitute “special category data” under UK GDPR (Article 9), which is subject to additional protection.

Kyro does not require users to provide medical information. Where users voluntarily disclose accessibility requirements or health-related information, such information will only be processed for safety, accessibility, or gym accommodation purposes and only where reasonably necessary.

Where required by applicable law, this information is processed on the basis of your explicit consent. You may withdraw this consent at any time, and doing so will not affect your general use of the Kyro platform. To withdraw consent, contact info@kyroapp.co.

Payment Information

Payments are processed securely by third-party payment providers. Kyro does not store full payment card details.

Device & Technical Information

We may automatically collect certain technical information, including IP address, device type, operating system, browser or app information, and location data (where enabled by the user).

With your permission, Kyro uses approximate (and, where you enable it, precise) location information while the app is in use, in the foreground, to help you discover nearby gyms and improve location-based functionality. Kyro does not track your location in the background. You can disable location access at any time through your device settings.

3. How We Use Your Information and Our Lawful Basis

Under UK GDPR we must have a lawful basis for each way we use your personal information. The table below sets out our main processing purposes and the corresponding lawful basis.

You may opt out of marketing communications at any time using the unsubscribe link in our messages or by contacting info@kyroapp.co.

4. Information Shared With Gyms

When you book a gym through Kyro, we may share relevant information with that gym, including your name, booking details, confirmation that required waivers or gym terms have been accepted, profile photo (where provided), age or date of birth where reasonably required, and emergency contact information where necessary for safety or emergency purposes.

Kyro aims to minimise the amount of personal information shared with gyms wherever reasonably possible.

Once a gym receives your information, that gym acts as a separate and independent data controller and is solely responsible for how it processes your personal information. We recommend you review the privacy policy of any gym you book through Kyro.

5. Legal Basis for Processing

Where applicable under UK GDPR and similar privacy laws, Kyro processes personal information based on contractual necessity, our legitimate business interests, legal obligations, your consent, and safety or security requirements. Section 3 above sets out which basis applies to each processing purpose.

Where users voluntarily provide health-related or accessibility-related information, such information is processed on the basis of explicit consent where required by law.

6. Data Retention

Kyro retains personal information only for as long as reasonably necessary for the purposes set out in this policy. As a general guide:

• Account information is retained while your account is active and for up to 24 months after closure, unless a longer period is required.
• Transaction and booking records are typically retained for 6 years to comply with UK tax and accounting requirements.
• Marketing consent records are retained until you withdraw consent, plus a short period to evidence the withdrawal.
• Health or accessibility information is retained only for as long as necessary for the safety or accommodation purpose, and then deleted.

Certain records may be retained for longer periods where legally required or reasonably necessary to resolve disputes, prevent fraud, or enforce agreements. You may request deletion of your account at any time by contacting info@kyroapp.co; some information may still be retained where required by law or for legitimate business purposes.

7. Security

Kyro uses appropriate technical and organisational measures to protect personal information. These measures may include encryption, secure third-party infrastructure providers, authentication protections, and restricted access controls.

However, no internet transmission or digital platform can be guaranteed completely secure. You are responsible for maintaining the confidentiality of your login credentials.

Where a personal data breach is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office and, where required by law, affected users without undue delay.

8. International Transfers

Because Kyro operates internationally and uses service providers located in various countries, personal information may be processed or accessed outside the UK and your country of residence.

Where we transfer personal information outside the UK, we ensure appropriate safeguards are in place as required by UK data protection law. These safeguards may include the UK International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses, or reliance on an adequacy decision for the relevant country.

9. Your Rights

Depending on applicable law and your location, you may have the right to access your personal information, correct inaccurate information, request deletion, object to certain processing, restrict processing, withdraw consent where processing is based on consent, and request data portability.

To exercise any of these rights, contact info@kyroapp.co. We will respond within the timeframes required by law.

Right to complain: if you are in the UK and believe we have not handled your personal information properly, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk. We would, however, appreciate the chance to address your concerns first.

10. Cookies & Analytics

Kyro may use cookies, analytics tools, and similar technologies to improve platform functionality, analyse usage and performance, maintain platform security, and improve user experience.

Where required by law, Kyro will request your consent before using non-essential cookies or analytics technologies, and will not set such technologies until you have given consent. You may manage your cookie preferences through your browser settings or through our consent tools where available.

11. Third-Party Services

Kyro uses trusted third-party providers for services including payment processing, cloud hosting, analytics, authentication, communications, customer support, and infrastructure services.

These providers may process personal information on Kyro's behalf as data processors, under contractual and security protections. A current list of our key processors is available on request by contacting info@kyroapp.co.

12. Children's Privacy

Kyro is intended for users aged 18 and over. We do not knowingly collect personal information from anyone under the age of 18.

If we become aware that we have collected personal information from a person under 18, we will take reasonable steps to delete that information. If you believe a person under 18 has provided us with personal information, please contact info@kyroapp.co.

13. Changes to This Privacy Policy

Kyro may update this Privacy Policy from time to time. For minor changes, continued use of the platform constitutes acknowledgement of the updated policy.

Where we make material changes — such as introducing new processing purposes or new categories of data — we will notify you and, where required by law, obtain your consent before those changes take effect.

14. Contact

For privacy-related questions, requests, or concerns, please contact:

KYRO APP LTD (company number 17052490)
Email: info@kyroapp.co
Website: kyroapp.co
Registered office address: available on the public register at Companies House.