Privacy Policy

Last updated: May 11, 2026

1. Who We Are

Up2Excel LLC ("AKMI", "we") operates the AKMI Human Performance platform. We are the data controller for coach account data and a data processor for client data managed by coaches.

2. Data We Collect

Coach data: name, email, password (hashed), avatar, methodology preferences, payment information, usage analytics.

Client data (entered by coaches): name, contact information, health history, biomechanical assessments, photos, videos, workout data, nutrition protocols, body composition measurements.

Automatically collected: IP address, browser type, device information, session duration, pages visited.

3. How We Use Data

• Provide and operate the Service
• Process assessments and generate reports
• Communicate account-related information
• Improve the Service through aggregated, anonymized analytics
• Comply with legal obligations

We do not sell personal data. We do not use client health data for advertising. We do not share individual data with third parties except as required to operate the Service (e.g., payment processing).

4. Legal Basis (GDPR)

For EU/EEA users, we process data under: (a) contract performance (providing the Service); (b) legitimate interest (improving the Service, security); (c) legal obligation (tax, compliance); (d) consent (optional communications).

5. Data Storage and Security

Data is stored on servers controlled by Up2Excel LLC. We implement industry-standard security measures including: encrypted connections (TLS), hashed passwords, per-coach data isolation, audit logging, and regular backups. Client data is isolated per coach — coaches cannot access other coaches' clients.

6. Your Rights (GDPR Article 15-22)

You have the right to:

• Access (Art. 15) — Request a copy of your personal data
• Rectification (Art. 16) — Correct inaccurate data
• Erasure (Art. 17) — Request deletion of your data
• Data portability (Art. 20) — Receive your data in a structured, machine-readable format
• Restriction (Art. 18) — Limit processing of your data
• Object (Art. 21) — Object to processing based on legitimate interest

The platform includes built-in GDPR tools: data export (comprehensive ZIP download) and data deletion with confirmation, accessible from your account settings.

7. Data Retention

Active account data is retained for the duration of the subscription. Upon account termination, data is retained for 30 days (export window), then permanently deleted. Backup copies may persist for up to 90 days before automatic purge.

8. Third-Party Services

We use carefully selected third-party service providers that may process data only where necessary to operate the Service:

• Payment processor — Secure subscription and checkout processing
• Security and infrastructure providers — Encrypted delivery, availability, and abuse protection
• Secure assessment processing providers — Analysis processing under data-protection controls; client data is not used to train third-party models

9. Cookies

We use essential cookies for: session management (HttpOnly, Secure, SameSite=Lax), language preference, and dark mode setting. We do not use advertising or tracking cookies.

10. Children

The Service is not intended for individuals under 16. We do not knowingly collect data from children. If you believe a child has provided data, contact us for immediate deletion.

11. International Transfers

Data may be transferred to and processed in the United States. For EU/EEA users, transfers are covered by Standard Contractual Clauses and our commitment to GDPR-equivalent protections.

12. Changes

We will notify you of material changes via email at least 30 days before they take effect.

13. Contact

Data Protection inquiries:
Up2Excel LLC
Email: carlos.uceira@gmail.com