Privacy Policy

Privacy Policy: TWINDO Sports Nutrition Advice

Last updated: 16 August 2026

Article 1. General

1.1 TWINDO Sports Nutrition Advice, Rietveen 2, 2912 SK Nieuwerkerk aan den IJssel, Chamber of Commerce registration number 95241647, respects your privacy and handles your personal data with care and in accordance with the GDPR.

1.2 This privacy policy applies to all our services: TWINDO One (with the ‘Today’, ‘Check’ and ‘Progress’ levels), the Sports Nutrition Advice Centre, presentations, workshops and web design.

Article 2. What data do we collect?

2.1 Through the contact form and the Sports Nutrition Advice Centre, we collect: your name, email address, and the subject and content of your message.

2.2 Through TWINDO One, regardless of your subscription level, we collect: your email address (for your personal access link; the app works without a password), your name, weight, goal (to improve performance, maintain weight, lose weight or gain weight) and main sport, your weekly training schedule (which days you train, the type of training and its intensity), your language preference, and subscription details (selected tier, payment status, active until date).

2.3 As part of the Check and Progress programme, we also collect your food diary: what and how much you eat and drink.

2.4 At Progressie, additional information may come up during a face-to-face coaching session that you choose to share yourself, such as medical information relevant to nutrition (allergies, intolerances, medication use, relevant medical conditions). We do not actively ask for this; you share it of your own accord.

2.5 For web design projects, we collect: name and contact details, company details, project-related information and materials provided.

Article 3. Purpose of data collection

3.1 We use your data to: answer your questions via the Sports Nutrition Advice Centre; generate your daily, automated nutritional advice within TWINDO One based on your profile and training schedule; for Check and Progress, compiling your periodic reports based on your food diary; for Progress, conducting your personal coaching sessions and compiling your comprehensive PDF report; processing your trial period and subscription, including payment transactions via our payment service provider Mollie; building and maintaining your website for web design projects; sending marketing communications about our services to those who have registered for the free masterclass; and complying with legal obligations, including the statutory retention period for tax purposes.

Article 4. Legal basis for processing

4.1 Performance of the contract: contact details, project details, app profile details and subscription details, and all data necessary for us to provide our services.

4.2 Express consent: for special categories of personal data, including your food diary (Check/Progressie) and any medical information you share with us during a Progressie coaching session.

4.3 Consent: to send marketing communications to those who have signed up for the free masterclass. You can unsubscribe at any time via the unsubscribe link in our emails.

4.4 Legal obligation: for data which we are legally obliged to retain, such as the 7-year tax retention obligation.

4.5 You may withdraw your consent to the processing of special categories of personal data at any time. This may mean that the food diary (Check/Progress) is no longer available, or that we are unable to continue a Progress coaching consultation in the same way.

Article 5. Special categories of personal data in the food diary

5.1 We collect and use data on what, when and how much you eat and drink in order to provide personalised nutritional advice as part of the Check and Progress programmes. This may constitute special categories of personal data (health data, Article 9 of the GDPR). Not because the data itself is medical in nature, but because we use it to draw conclusions about your dietary habits and physical health.

5.2 We process this data solely on the basis of your explicit, separately granted consent. We request this in advance, when you log in to TWINDO One, via a mandatory consent screen featuring a separate, actively tickable checkbox. We record your consent, including the date and time and the version number. If the text of this consent changes at a later date, we will ask for your consent again.

5.3 You are not required to provide more information than is necessary for the purpose of the coaching; medical diagnoses or details of medication do not need to be included in the diary itself.

Article 6. Website statistics

6.1 We use anonymous website statistics to improve our website. We do not set any cookies or store any personal data for this purpose. The data collected is completely anonymised and cannot be traced back to individual persons.

Article 7. Local storage in TWINDO One

7.1 TWINDO One is a progressive web app (PWA): you can install the app on your device, or simply use it via your browser. In both cases, to ensure it can operate quickly and even without an internet connection, the app stores some of your data locally on your own device (using the localStorage browser technology) and caches screen files via a service worker.

7.2 This is functional, strictly necessary storage required for the app to work. It does not involve any tracking or marketing cookies, and no separate consent is required for this. You can delete this local data yourself via your browser settings (“clear site data”).

Article 8. Hosting, server location and data storage

8.1 We use the following parties, who act as data processors, to provide our services:

8.2 Namecheap (EasyWP) provides hosting for our website and TWINDO One. Depending on the hosting package chosen, this may take place in the United States, the United Kingdom or the European Union (Amsterdam). Namecheap employs appropriate security measures, including Standard Contractual Clauses (SCCs), as a mechanism for data transfers when data is processed outside the EEA.

8.3 Google Workspace and Google Sheets are used to store your app profile, training week and food diary data, and to send app-related emails. This processing takes place within the European Union. A data processing agreement has been entered into with Google.

8.4 Mollie handles payment processing for TWINDO One subscriptions. This processing takes place within the European Union (the Netherlands).

8.5 We use MailerLite for email marketing to those who have signed up for the free masterclass: this includes both the masterclass communications themselves and other marketing communications about our services to that same group. We do not use any other email addresses or lists for marketing purposes. MailerLite operates its own data centres located within the European Union (Germany and the Netherlands) and offers a Data Processing Agreement (DPA), with standard contractual clauses in the event that data is processed outside the EEA.

8.6 We also host the websites we build for our web design clients with Namecheap (EasyWP), in the same way as our own website (see clause 8.2). Neither we nor the client choose the server location; this is determined by Namecheap, depending on the hosting package used.

8.7 If you have any queries regarding the specific server location, please contact us via helpdesk@twindo-sportvoedingsadvies.nl.

Article 9. Retention periods

9.1 Contact form and Sports Nutrition Advice Centre: up to 2 years after the last contact.

9.2 Email correspondence: up to 2 years.

9.3 TWINDO One profile, training and nutrition diary data: for as long as your subscription is active, and for up to 2 years after it ends.

9.4 Subscription and payment records: 7 years, in accordance with the statutory tax retention requirement.

9.5 Web design client data: throughout the project and for a further 7 years, in accordance with the statutory retention period for records.

9.6 Once the retention period has expired, we will delete your data, unless a legal obligation requires us to retain it for a longer period.

Article 10. Sharing of data

10.1 We never sell your data to third parties. We only share your data with:

10.2 Namecheap, for website hosting and TWINDO One.

10.3 Google, for the storage of your app profile and food diary data, and for sending emails from within the app.

10.4 Mollie, for processing your subscription payment. Mollie receives the payment details required to process the payment and, in the case of a subscription, the standing authorisation (via iDEAL, credit card or Bancontact). We never view or store your full card or bank details ourselves.

10.5 MailerLite, for sending out masterclass and marketing communications to those who have signed up for the free masterclass.

10.6 Competent authorities, where required by law.

10.7 Registered dietitians, solely for the purposes of your health and safety and only with your express consent (see also Article 13 of our Terms and Conditions).

Article 11. Security

11.1 We take appropriate technical and organisational measures to protect your data, including: an HTTPS connection, secure servers with regular updates, daily backups, restricted access to personal data, and access to TWINDO One exclusively via a personal, unique access link, without passwords that can be reused on other services.

Article 12. Automated decisions

12.1 We do not make any automated decisions about you that have legal consequences or otherwise significantly affect you.

12.2 TWINDO One does, however, automatically calculate your daily nutritional advice (macronutrients, timing) from your profile and training schedule, using complex algorithms based on evidence-based, scientific nutritional principles. This is informative advice, not a binding decision concerning you: you are free at all times to follow or disregard the advice, and this has no legal or otherwise significant consequences for you within the meaning of Article 22 of the GDPR.

Article 13. Your rights

13.1 Under the GDPR, you have the following rights: the right of access to your data, the right to rectification or erasure, the right to restriction of processing, the right to object, the right to withdraw your consent, the right to data portability, and the right to lodge a complaint with the Dutch Data Protection Authority (authority-personal-data.nl, tel. 088 – 1805 250).

13.2 You can submit requests via helpdesk@twindo-sportvoedingsadvies.nl. We will respond within one month. In the case of complex requests, this may take up to three months; you will be notified of this in good time.

Article 14. Children

14.1 Our services, including TWINDO One, are not aimed at children under the age of 16. If we inadvertently receive data from a child, we will delete it immediately upon being notified.

Article 15. Amendments

15.1 This privacy policy is subject to change. The most recent version is always available on our website. Any changes will be announced by publication on our website; we will not inform you of this separately or proactively.