PAICE™ — Data Practices Summary for Platform Partners

NxtStep Athletics, Inc. · Companion to our Privacy Policy · Alpha/Beta · 25 June 2026

PAICE is an invitation-only, pre-commercial advanced AI running-training service, the access to, or testing of which is subject to a separate confidentiality agreement. This one-page (front and back) summary describes how we handle data accessed through your developer API. It accompanies, and is governed by, our full Privacy Policy at nxt-step.com/privacy.

What We Access & Why — Only the fitness and health data a user explicitly connects, used solely to generate that user's personalized running guidance and surface safety considerations. We request the minimum scopes needed and nothing more.

What We Never Do — We never sell user data; never use it for advertising or marketing; never share it with data brokers or advertising networks; and never use API-sourced data for any purpose other than providing health-and-fitness features to the user who connected it.

Consent — Access is explicit, granted per source and per data type through each platform's own authorization flow, and is revocable at any time in PAICE or in the source platform's settings. We never interfere with a platform's consent or authorization prompts.

AI use & Transparency — Connected data is processed by automated systems, including AI, to produce the user's guidance. Where third-party AI services are used, they operate under Zero Data Retention terms, and we do not permit any identifiable health data to be used to train third-party foundation models.

Security (Voluntary HIPAA-Grade) TLS 1.3 with Perfect Forward Secrecy in transit; AES-256 at rest; least-privilege role-based access with MFA; immutable audit logs (target six-year retention); breach notification as required by law. NxtStep Athletics, Inc. is not a HIPAA covered entity; "HIPAA-Grade" describes the safeguards we adopt, not a regulatory status.

Retention & Deletion — Data is retained only as long as needed to provide the service and meet legal/audit obligations. Users can delete their data on request; per-user encryption keys are destroyed so the underlying data becomes unrecoverable, subject to limited legal/safety retention.

Sharing — Limited to subprocessors under data-protection/business-associate terms (cloud infrastructure) and Zero Data Retention terms (AI services); IRB-approved research under separate participant consent; disclosures required by law or safety; and corporate transactions with notice. No other sharing.

Compliance & Scope — We honor the CPRA and other U.S. state privacy laws. Alpha/Beta is offered to U.S.-based users only; EEA/UK/Swiss transfer safeguards will be in place before any release in those regions. We comply with each platform's developer terms — where they are stricter than our policy, theirs control. Users must be 19 or older. PAICE is not a medical device and does not diagnose.

Platform Our Key Commitments to You
Apple Health (HealthKit) Used only to provide health/fitness features to the user; no advertising or use-based data mining; no sale to ad platforms, data brokers, or resellers; explicit informed consent; not stored in iCloud.
Garmin Connect Fully informed consent before any data transfer; AI-transparency disclosure provided (above); compliance with program and branding requirements.
Oura No disclosure, sale, license, or lease of Oura data to any third party — including advertisers or data brokers — even with user consent; marketing opt-out at point of collection; notice to Oura on merger or acquisition.
Polar Consent via Polar's authorization flow; never used to build a competing service; we bear full responsibility for privacy-law compliance; disconnect and deletion honored.
Coros · Amazfit/Zepp · Moxy Monitor · Whoop · Strava · CGM Consent-based access; used only to provide and improve PAICE; never sold or used for advertising; disconnect and deletion honored, consistent with each source's terms.

Contact

NxtStep™ Athletics, Inc.

Partner & Privacy Inquiries: legal@nxt-step.com

1500 NW Bethany Blvd. STE 200

Beaverton, OR 97006