Privacy Policy

Effective 5 November 2026 · Applies to the Athletic Sparks app (shown as “Spark” on iPhone) and the member services behind it.

1. Who we are

Athletic Sparks is the member app of Lecao Athletic Base Co., Ltd (“LAB”, “we”, “us”), a strength and conditioning gym at 129 Quoc Huong, An Khanh Ward (Thao Dien), Ho Chi Minh City, Vietnam (business registration number 0317685169). LAB decides how and why your personal data is processed in the app and in the member records behind it, and is responsible for it under Vietnam's Law on Personal Data Protection (Law No. 91/2025/QH15) and Decree No. 356/2025/ND-CP.

This policy explains what we collect, why, who we share it with, how long we keep it, and the choices you have. It covers the app and the member account it connects to. It does not cover other websites or apps that we link to.

2. Data we collect

You can use the app only after LAB invites you. Some of the data below comes from you in the app; some is recorded by LAB staff when you join or train with us and is shown to you in the app.

CategoryExamplesWhere it comes from
Identity and contactName, email address, phone number, member numberLAB when you join; you can update your name and phone in the app
Account and sign-inPassword (stored only as a one-way hash), invitation code (stored only as a hash), sign-in sessions with the date and the device type and app version your phone reportsYou, and your phone when you sign in
Membership profileDate of birth, gender, address, membership start date and status, assigned coach. If you agree to an assessment, coaches may record height, weight and body compositionLAB staff
Emergency contactThe name and phone number of a person you chooseYou or LAB staff
Profile photoA photo you take or choose in the app, or that LAB adds with your agreementYou or LAB staff
Health informationInjuries, their status and updates, and notes that help coaches adapt your training. See section 3You or your coach
Training activityBookings, cancellations, waitlist entries, check-ins and attendance, sessions used, coach training notes, monthly goal progressYou and LAB staff
Purchases and billingPackages and credits, orders, invoices, amounts, payment status and method (for example cash at reception). The app does not collect card numbersYou and LAB staff
Waiver and agreementsWhich version of the training waiver you accepted and whenYou
PreferencesYour notification choices and app appearanceYou
Technical dataIP address and request details in server logs, used for security and to keep the service runningYour phone, automatically

We do not use advertising, analytics or tracking tools in the app. We do not track you across other companies' apps or websites, and we do not sell your personal data.

3. Health information

Information about injuries and physical condition is sensitive personal data under Vietnamese law. We process it only to keep you safe and to adapt your training, with your explicit consent, which you give when you add an injury or agree to an assessment. Only LAB staff who coach or look after you can see it. We never use it for marketing or advertising, and we never share it with insurers or employers. You can view your injury records in the app, and you can ask us to correct or delete them at any time.

LAB is a gym, not a medical provider. Injury notes are training notes, not medical records or advice.

4. Camera, photos and calendar

You can turn these permissions on or off at any time in iPhone Settings. The rest of the app keeps working without them.

5. How we use your data

We do not make automated decisions about you that have legal or similarly significant effects.

We process your data with your consent. You give it when you activate your account in the app, where we link to this policy before you continue, when you accept the training waiver, and when you use specific features such as injury notes and profile photos. We may also process data without consent where Vietnamese law allows it: to perform your membership contract, to meet legal obligations such as accounting and tax rules, or to protect your life or health in an emergency.

You can withdraw consent at any time by emailing us (see section 14). Withdrawing consent does not affect processing that took place before, and we may be unable to provide parts of the service that depend on it.

7. Who we share it with

Apple distributes the app through the App Store under its own privacy policy. We do not receive your Apple Account details.

8. Where your data is stored

Our servers and backups are run by AWS in Singapore. Email delivery and some provider support services may involve processing in other countries, including the United States. When personal data leaves Vietnam, we transfer it in line with Vietnamese personal data protection law and require our providers to protect it to the same standard as this policy.

9. How long we keep it

10. Your rights and account deletion

Under Vietnamese law you have the right to:

To delete your account, email [email protected] from the email address on your membership with the subject “Delete my Athletic Sparks account”, or ask at the front desk. We confirm the request, then delete your app account and the personal data linked to it, or make it anonymous, except records the law requires us to keep, as described in section 9. Step-by-step instructions are on our Support page.

For any other request, email us. We may ask you to confirm your identity first. We acknowledge every request within 2 working days and complete it within the time limits set by Vietnamese law. For example, we complete a deletion request within 20 days, or 30 days where our service providers also need to act.

11. Security

Data travels between the app and our servers over encrypted HTTPS connections. Passwords and invitation codes are stored only as one-way hashes. On your iPhone, your sign-in is kept in the iOS Keychain and does not leave the device in backups. Staff access is limited by role and important changes are logged. No system is perfectly secure; if a breach affects your data, we will notify you and the authorities as the law requires.

12. Children

LAB runs youth training programmes. We process a child's data only with the consent of a parent or guardian, and of the child where the law requires it. Parents and guardians can contact us to access, correct or delete their child's data.

13. Changes to this policy

We will post any change on this page with a new effective date. If a change materially affects how we use your data, we will tell you in the app or by email before it applies, and ask for your consent again where the law requires it.

14. Contact us

Lecao Athletic Base Co., Ltd 129 Quoc Huong, An Khanh Ward (Thao Dien), Ho Chi Minh City, Vietnam Email: [email protected] Phone: +84 929 099 199