Privacy Policy

R&D Technology - Pascal ROMBAUX is committed to protecting your personal data in accordance with EU Regulation 2016/679 of 27 April 2016 (GDPR) and the Belgian law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.

This privacy policy applies to all data collected in connection with the use of the RideComposer software and the ridecomposer.com website.

1. Data Controller

The data controller for personal data is:

R&D Technology - Pascal ROMBAUX
Sole proprietorship (natural person) under Belgian law
Belgium
Email: info@ridecomposer.com
Website: www.ridecomposer.com

2. Data Collected

R&D Technology - Pascal ROMBAUX collects and processes the following categories of data:

2.1 Identification data

• First and last name
• Email address
• Country of residence
• Cycling discipline(s) practised
• Login credentials (username, hashed password)

2.2 Billing data

Payments are handled by Lemon Squeezy as merchant of record (our authorised reseller), with card processing delegated to Stripe Inc. as payment sub-processor. R&D Technology - Pascal ROMBAUX does not access or store bank card data on its servers. Only transaction information (amount, date, reference) is retained for accounting purposes.

2.3 Software usage data

• Connection logs (date, time, anonymised IP address)
• Software version used
• Licence activation information (device identifier, activation date)
• Diagnostic and performance data (in case of error, with consent)

2.4 Ride metadata (Pro plan only)

If the User activates Cloud synchronisation (Pro plan), ride metadata is processed: session title, duration, discipline, track BPM, pedagogical zones. No audio file is ever transmitted or stored by R&D Technology - Pascal ROMBAUX.

3. Purposes and Legal Bases for Processing

4. Data Retention Periods

• Active account data: retained for the entire duration of the subscription.
• Data after termination: retained for 3 years for dispute management and legal obligations.
• Billing data: retained for 7 years in accordance with Belgian accounting obligations.
• Rides and metadata (unconverted trial): deleted 30 days after the end of the trial period.
• Connection logs: retained for a maximum of 12 months.

5. Sub-processors and Data Recipients

R&D Technology - Pascal ROMBAUX uses the following sub-processors to deliver the service. Each is subject to contractual confidentiality and security obligations compliant with the GDPR:

R&D Technology - Pascal ROMBAUX does not sell, rent or share your personal data with third parties for commercial purposes.

6. Transfers Outside the European Union

Some of our sub-processors may process data outside the European Union (in particular in the United States). In such cases, transfers are governed by appropriate mechanisms in accordance with the GDPR (Standard Contractual Clauses of the European Commission, or recognised equivalents).

7. Your Rights

In accordance with the GDPR, you have the following rights over your personal data:

To exercise your rights, contact us at: info@ridecomposer.com. We will respond within a maximum of 30 days. If you receive no response or an unsatisfactory one, you may lodge a complaint with the Belgian Data Protection Authority (DPA): www.dataprotectionauthority.be.

8. Data Security

R&D Technology - Pascal ROMBAUX implements appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction or disclosure:

• Encryption of data in transit (TLS 1.3)
• Encryption of data at rest (AES-256)
• HMAC-SHA256 licence mechanism
• Data access restricted to authorised personnel
• Regular security audits
• Security incident management policy

9. Cookies and Tracking Technologies

The ridecomposer.com website uses strictly necessary cookies for site operation (authentication, session preferences) and analytical cookies to measure audience (Google Analytics 4), in accordance with your preferences. No advertising or third-party profiling cookies are used.

Audience measurement only runs if you accept it. Nothing is sent before you choose, and you can change your mind at any time:

You can also clear these cookies from your browser settings, or contact us.

10. Children

RideComposer is a professional software intended for certified instructors. We do not knowingly collect personal data from persons under the age of 18. If you believe that a minor has provided us with personal data, please contact us at the address below.

11. Amendments to this Policy

R&D Technology - Pascal ROMBAUX reserves the right to amend this privacy policy at any time. Any material amendment will be notified by email at least 30 days before it comes into force. The current version is always available at ridecomposer.com/privacy.html.

12. Contact

For any questions regarding the protection of your personal data or to exercise your rights:

R&D Technology - Pascal ROMBAUX — Data Protection Officer
Email: info@ridecomposer.com
Website: www.ridecomposer.com