LEGAL

Privacy Policy

Last updated: 13 October 2026

01Introduction

Empowerly respects your privacy and aims to handle your personal data carefully and transparently.

This Privacy Policy explains what personal data Empowerly may collect when you use the Empowerly website and membership platform, why this information is processed, how it is used and protected, and what rights you may have in relation to your personal data.

Empowerly is operated as a sole proprietorship registered in the Netherlands.

Business details:
Empowerly
Sole proprietorship
Kanaalmuur 17
3991 VT Houten
The Netherlands
Chamber of Commerce (KvK): 42168393
VAT ID: NL005552162B68
Privacy contact: fit@empowerly.nl

02Information we collect

Depending on how you use Empowerly, we may process the following categories of personal data:

Account information:

email address
first name, where provided
internal user/account identifiers
authentication and account-verification information
login and session information

Membership information:

membership status
payment-provider customer identifier
subscription identifier
information required to connect a payment or subscription to an Empowerly account

Membership activity:

habits created by you
habit schedules and completion history
workout activity and completion history
challenge participation and progress
achievements
recipe favourites
meal-plan choices and swaps
grocery-list completion
onboarding status

Testimonials: If you voluntarily submit a testimonial, we may process the information you provide, such as your name, testimonial, additional explanation and your recorded consent.

Communications: When you contact Empowerly, we may process your email address, the contents of your message and other information you choose to provide.

Withdrawal requests: If you use the online withdrawal form, we process your name, the email address used for the purchase, the optional purchase date, the optional Plug&Pay order or subscription number, the request reference and the date and time of submission. This information is processed to receive, administer and respond to your withdrawal request.

Empowerly does not store full payment card details, bank-account details or other full payment credentials on the membership platform. Payments are handled by external payment providers.

03How we use your information

We may process personal data in order to:

create and manage your Empowerly account
authenticate users and secure accounts
provide access to membership features
determine whether a membership is active
connect subscriptions and payments to the correct account
provide habit, workout, challenge, meal-planning and progress functionality
remember preferences and activity within the membership
provide customer support
process cancellation, withdrawal and privacy requests
prevent misuse and protect the security of the platform
maintain necessary technical and operational records
comply with applicable legal obligations
display testimonials where the user has agreed to publication

Depending on the processing activity, processing may be necessary to perform an agreement with you, comply with a legal obligation, pursue a legitimate interest, or be based on your consent.

Where processing is based on consent, you may withdraw that consent for future processing.

04Account information and authentication

Empowerly allows users to create an account using email and password authentication and may also allow users to sign in using Google.

Passwords are handled through the authentication infrastructure used by the platform. Empowerly does not have access to your plain-text password.

Account information is used to authenticate you, maintain your session, protect your account and connect membership access to the correct user.

When you use Google sign-in, information necessary to authenticate your account, such as your name and email address, may be exchanged with Google as part of the authentication process.

05Payments and subscriptions

Membership payments are processed through Plug&Pay and its payment infrastructure, which may include payment service providers such as Mollie.

Empowerly's membership platform stores only limited information needed to manage membership access, such as:

membership status
subscription identifier
payment-provider customer identifier

When necessary, Empowerly's server may retrieve current subscription information from Plug&Pay to verify whether a membership is valid and to connect a subscription to the correct Empowerly account.

Empowerly does not use stored webhook or technical log data as proof of an active membership. Current subscription status is verified with the relevant payment system where required.

Payment providers may independently process information necessary to complete payments, prevent fraud, maintain financial records and comply with their legal obligations. Their own privacy terms may apply to that processing.

06Lifestyle and membership activity

Empowerly allows members to record lifestyle activity such as habits, workout completion, challenge progress, favourite recipes, meal-plan choices and grocery-list progress.

Empowerly does not provide fields specifically intended for storing medical diagnoses, medication information, health conditions, allergies, body measurements, weight, sleep data or mood information.

Custom habit names contain free text. For your privacy, please avoid entering medical diagnoses, medication details or other sensitive health information in custom habit names.

If you voluntarily enter sensitive information into a free-text field that was not designed for that purpose, please be aware that it may nevertheless be stored as part of the information you provide.

Empowerly is a healthy lifestyle platform and is not intended to function as a medical record or healthcare service.

07Browser storage and cookies

Empowerly uses browser storage and similar technologies where necessary to provide core website functionality.

For example, browser storage may be used to:

keep you signed in
identify your account during an authenticated session
safely return you to the appropriate page after authentication
remember essential interface state

At the time of this Privacy Policy, Empowerly does not use advertising pixels or third-party advertising trackers as part of the membership website.

Empowerly's website fonts are served locally and are not loaded from Google Fonts at runtime.

If non-essential analytics, advertising or tracking technologies are introduced in the future, this Privacy Policy and, where required, consent mechanisms will be updated.

08Third-party services

Empowerly relies on third-party service providers to operate parts of the website and membership service.

These may include services for:

website hosting and cloud infrastructure
authentication
payment and subscription processing
payment execution
email delivery
website security and traffic delivery

Current services include or may include:

Lovable Cloud for website, application, authentication and database infrastructure
Cloudflare for network and website delivery infrastructure
Plug&Pay for membership payment and subscription processing
Mollie as part of payment processing
Google when a user chooses Google authentication
Lovable's managed email service for transactional emails, such as withdrawal-request confirmations, sent from the subdomain notify.empowerly.nl

These providers may process personal data only to the extent necessary for the services they provide or in accordance with their own applicable responsibilities and privacy terms.

Empowerly does not make claims in this Privacy Policy about a provider's specific data-centre location where that information has not been independently confirmed.

09Data retention

Empowerly keeps personal data only for as long as reasonably necessary for the purpose for which it was collected, to provide the service, resolve disputes, maintain security, or meet applicable legal obligations.

Different categories of information may therefore have different retention periods.

Withdrawal request information is retained only for as long as reasonably necessary to handle the request, comply with applicable legal obligations, and establish, exercise or defend legal claims. Retention periods are assessed according to the purpose and applicable legal requirements. Records forming part of financial administration may be subject to separate statutory retention obligations.

Successfully processed technical Plug&Pay webhook/event logs maintained by Empowerly are automatically removed after 90 days where they are no longer required for reconciliation or manual review.

Unresolved records that may still be necessary to connect a previous payment to an account or investigate a payment issue may be retained for longer while the matter remains unresolved.

Payment providers may retain transaction and financial records for periods required by applicable financial, tax or other legal obligations.

Where an Empowerly account is deleted, user-owned application data linked to that account is designed to be removed together with the account, subject to information that may need to be retained separately for legitimate legal, security, administrative or dispute-resolution purposes.

Information may also remain temporarily in backups where applicable until those backups are overwritten or deleted in accordance with the relevant provider's procedures.

11Data security

Empowerly uses technical and organisational measures intended to protect personal data against unauthorised access, loss, misuse or alteration.

Measures used by the platform include, where applicable:

authenticated access to member data
user-level data isolation
server-side membership and authorization checks
restricted access to payment integration information
server-side storage of API credentials and secrets
minimisation of technical webhook logging
protected webhook and reconciliation processes

No online service can guarantee absolute security.

12Your privacy rights

Depending on the circumstances and applicable data-protection law, you may have rights relating to your personal data, including the right to request:

access to your personal data
correction of inaccurate personal data
deletion of personal data
restriction of processing
objection to certain processing
data portability where applicable
withdrawal of consent where processing is based on consent

Some rights are subject to legal conditions and exceptions. For example, Empowerly may need to retain certain information where this is required by law or necessary for the establishment, exercise or defence of legal claims.

To make a privacy request, contact: fit@empowerly.nl

Please contact us from the email address associated with your Empowerly account where possible. We may need to verify your identity before completing a request in order to protect your personal information.

You may also have the right to lodge a complaint with the competent data-protection supervisory authority. In the Netherlands, this is the Autoriteit Persoonsgegevens.

13International data processing

Some service providers used by Empowerly may operate internationally or use infrastructure in more than one country.

Where personal data is transferred outside the European Economic Area and applicable law requires safeguards, appropriate transfer mechanisms must be used by the relevant party.

Empowerly does not state that a particular international transfer occurs unless this has been confirmed for the relevant provider and service.

14Children

Empowerly is not designed as a service for children.

If Empowerly becomes aware that personal data has been collected from a child in circumstances where valid authorisation was required but not obtained, appropriate steps may be taken to address the situation.

15Changes to this Privacy Policy

Empowerly may update this Privacy Policy when the service, technology, legal requirements or data-processing practices change.

The latest version will be made available on this page. Where appropriate, significant changes may also be communicated through the website or another suitable method.

16Contact

For questions about this Privacy Policy or the way Empowerly handles personal data, contact:

Empowerly
Kanaalmuur 17
3991 VT Houten
The Netherlands
Chamber of Commerce (KvK): 42168393
VAT ID: NL005552162B68
Email: fit@empowerly.nl