GDPR

GDPR-Compliant Gym Software

Sessy is gym membership software for EU privacy law: EU-hosted platform data, a published Article 28 processor addendum, public sub-processor list, and documented retention.

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Article 28 processor terms

The published Processor addendum is Sessy’s written GDPR data processing agreement with your gym — no separate DPA request needed.

EU-primary hosting

Core platform data is processed primarily on Google Cloud / Firebase in the EU.

Public sub-processors

Named providers, purposes, and typical locations are listed on the sub-processors page, which forms part of the addendum.

Documented retention

Technical retention rules include a 3-year session TTL and automatic newsletter cleanup after 1 year.

Is Sessy GDPR-compliant gym membership software?

Yes — for gyms in the EU/EEA, Sessy is built around GDPR roles and published legal documents. Your gym is the data controller for member data in Sessy; Sessy is the processor for that data. The written Article 28 terms are the Processor addendum. Sub-processors are listed on the Sub-processors page (part of the addendum). Core platform data is hosted primarily in the EU on Google Cloud / Firebase. This page summarises what Sessy publishes today — it is not legal advice.

At a glance (quotable facts)

  • Hosting: Google Cloud / Firebase — EU (primary) for cloud hosting and application infrastructure (Sub-processors, Privacy statement).
  • Processor contract: The Processor addendum is the Article 28 GDPR processing agreement; no separate copy is required.
  • Sub-processors: Public list by processing type at Sub-processors; material changes are published there; providers may object within 30 days (Processor addendum).
  • Retention: Sessions use a 3-year TTL; newsletters older than 1 year are removed by scheduled cleanup (Data storage & retention).
  • Health data (Art. 9): Optional, explicit, withdrawable health-data consent for members (since version 11.0.0) — configured via subscription/member preferences (Subscription types, release notes).
  • In-app Sessy AI (platform mode): Routes via Opper (EU) to Microsoft Azure in the EU; Sessy does not train models on gym data; default route is not used to train the model (Sub-processors, Privacy statement).
  • MCP / external AI: If a gym connects Claude, ChatGPT, Cursor, or another MCP client, that AI vendor is the gym’s processor, not Sessy’s (Sub-processors, Connect AI agent).
  • Payments: Stripe may process outside the EEA; Sessy does not store full card numbers (Sub-processors).
  • Website support chat: Chatwoot, self-hosted by Sessy in the EU — separate from gym member databases (Sub-processors).

Roles: controller, processor, and your documents

TopicWhere it is documented
Gym = controller, Sessy = processor for member dataProcessor addendum, Privacy statement
Article 28 contractProcessor addendum
Sub-processor authorisation and objectionsProcessor addendum §5, Sub-processors
Security measures (Art. 32)Processor addendum §4
Breach notification to gymsProcessor addendum §8
Member rights (when Sessy is controller vs processor)Privacy statement

Dutch gyms may use the authoritative Verwerkersaddendum and Subverwerkers pages; the English addendum states the Dutch version prevails.


Data location and sub-processors

Sessy processes personal data primarily in the European Union. The Sub-processors page groups providers by type:

  1. Cloud hosting — Google Cloud / Firebase (EU, primary)
  2. Payments — Stripe (may include non-EEA processing)
  3. Customer support (website) — Chatwoot, self-hosted in the EU
  4. AI inference (in-app, platform mode) — Opper (EU) and Azure (EU)
  5. Analytics and security (website) — Google Analytics, reCAPTCHA

Google Cloud / Firebase is not used to train AI models (Sub-processors).


Retention and cleanup

System retention behaviour is documented technically in Data storage & retention:

  • Sessions: _meta.ttl set to 3 years; older session documents are removed during cleanup.
  • Newsletters: Published or draft newsletters older than 1 year are deleted, including referenced images.
  • Other jobs: Examples include 90-day cleanup for backend user activation records and inactive device tokens (same doc).

Health data and member consent (GDPR Article 9)

Notes or preferences may involve special-category (Article 9) data (for example injuries). The gym must have a valid legal basis. Sessy supports optional, explicit, withdrawable health-data consent in the app (not pre-ticked) — see Subscription types and version 11.0.0.


Sessy AI and MCP

Platform mode (default): Staff use in-app Sessy AI; requests go to Opper and the default Azure EU model. Training and retention for that route are described in the Privacy statement and Sub-processors.

BYOK: The gym’s own Opper account and model — the gym chooses region and vendor terms (Processor addendum).

MCP: External AI tools connected via agent tokens are the gym’s processor, not listed as Sessy sub-processors (Sub-processors, Connect AI agent).


FAQ

Does Sessy provide a GDPR data processing agreement (DPA)?

Yes. The Processor addendum is the Article 28 agreement. It applies when you use the platform as a Provider.

Where can I see which companies process data for Sessy?

On the Sub-processors page, updated when providers change.

Where is gym member data stored?

Primarily on Google Cloud / Firebase in the EU (Sub-processors, Privacy statement). Some services (for example Stripe payments) may process outside the EEA with appropriate safeguards.

How long does Sessy keep sessions and newsletters?

Sessions: up to 3 years (TTL). Newsletters: automatic deletion after 1 year (Data storage & retention).

Does Sessy train AI on my gym’s member data?

No. Sessy does not use Provider or Member data to train AI models (Processor addendum §7, Sub-processors).

Who is the processor if we connect ChatGPT or Claude via MCP?

The AI vendor the gym selects — not Sessy (Sub-processors).

Does Sessy store credit card numbers?

No full card numbers — payment processing uses Stripe (Sub-processors).

Is website chat the same as Sessy AI in the app?

No. Chatwoot on sessy.app is self-hosted in the EU and does not access gym member databases (Sub-processors).


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