Privacy Policy

Last updated: 30 September 2026

This Privacy Policy of Simma Pty Ltd ACN 653 388 157 (us, we, our) sets out how we treat the personal information that we collect, use and disclose and our procedures regarding the handling of personal information, including the collection, use, disclosure and storage of information, as well as the right of individuals to access and correct that information. We operate the Platform called Simma, which includes the website with domain name www.getsimma.com and ancillary platforms which facilitate the operation of the Simma applications (Platform).

From time to time, we may revise or update this Privacy Policy or our information handling practices. If we do so, the revised Privacy Policy will be published on the Platform.

We may collect personal information in order to conduct our business, to provide and market our services and to meet our legal obligations. By using the Platform or our services, or by providing any personal information to us, you consent to the collection, use and disclosure of your personal information as set out in this Privacy Policy.

The types of personal information we collect and hold

The types of personal information we may collect and hold includes (but is not limited to) personal information about:

• your name, address, contact telephone number and other contact details such as your email address;
• payment information (such as credit card or bank details);
• training, wearable and competition data as set out below;
• sensitive information as set out below;
• other personal information required to provide our services in specific cases; and
• details of your use of our products or services.

You are not obliged to provide personal information to us. However, in many cases, if you do not provide personal information to us, we may not be able to supply the relevant functionality of the Platform.

In some circumstances, you may provide to us, and we may collect from you, personal information about a third party. Where you provide the personal information of a third party, you must ensure that the third party is aware of this Privacy Policy, understands it and agrees to accept it. If you are providing us with personal or sensitive information on behalf of a person who is under the age of 18 that you are the parent or guardian of, you understand that you are consenting to this Privacy Policy on their behalf as their legal guardian.

If it is necessary to do so, or if you decide to provide it, we may also collect sensitive information (Sensitive Information) from you. Sensitive Information includes but is not limited to information about or pertaining to your:

• health, including physiological and recovery metrics recorded by wearable devices (for example heart rate, heart rate variability, sleep and readiness indicators);
• injury, illness or other health information you or your coach record on the Platform;
• training and performance data that reveals information about your physical condition; and
• other health related information reasonably required by us to provide our services to you.

We will only collect Sensitive Information from you if you agree to provide it to us. We will only use Sensitive Information in accordance with the Privacy Act and for the purposes for which it is provided. We retain Sensitive Information in accordance with the Data retention section below, and delete or de-identify it when it is no longer required to provide our services, unless we are required or permitted by law to retain it.

Training, health and wearable data

Simma is a coaching intelligence platform. In addition to the information described above, we collect and process training and physiological data about athletes, including:

• workout and session data (for example swim, bike and run sessions, pace, power, stroke and distance metrics);
• physiological and recovery metrics recorded by wearable devices (for example heart rate, heart rate variability (HRV), sleep, and readiness indicators);
• competition and meet results, including results files provided by coaches, clubs or timing providers; and
• training plans, compliance information and coach notes.

This data is collected:

• from wearable devices and connected services that an athlete authorises (for example Garmin Connect or Apple Health), via each provider’s authorised interfaces and subject to that provider’s terms;
• from files uploaded by a coach or club (for example meet results files); and
• through the athlete’s or coach’s use of the Platform.

Much of this data is health information and therefore Sensitive Information under the Privacy Act 1988 (Cth). We only collect it with consent — given by the athlete when they connect a device or service, or by their parent or guardian where the athlete is under 18 — and we use it solely to provide our services: computing training load, readiness and performance analytics and making them available to the athlete and to the coach or squad the athlete has chosen to share their data with.

Athletes may disconnect a wearable or connected service at any time, which stops further collection from that source.

How personal information is collected and held by us

We collect personal information in the following ways:

• when you create an account or complete a form on the Platform;
• when you submit personal information through the Platform (such as when you send us a message or fill out an online form);
• when you connect a wearable device or third party service to your Simma account;
• in person, for example, when you engage with our employees, agents, or customer service representatives; and
• in the course of providing services to you.

We store personal information in computer storage facilities. We take steps to protect your personal information against loss, unauthorised access, use modification or disclosure. Some examples of the steps we take to protect your personal information include:

• ensuring there are suitable password protection measures and access privileges in place to monitor and control access to our IT systems;
• imposing restrictions on physical access to paper files;
• requiring any third parties engaged by us to provide appropriate assurances to handle your personal information in a manner consistent with Australian law; and
• taking reasonable steps to destroy or de-identify personal information after we no longer need it for our business or to comply with the law.

Collection of personal information through activity

Information that may identify you as a user may be gathered during your access with the Platform.

The Platform may include pages that use ‘cookies’. A cookie is a unique identification number that allows the server to identify and interact more effectively with your computer or device. The cookie assists us in identifying what our users find interesting on the Platform.

A cookie may be allocated each time you use the Platform. The cookie does not identify you as an individual in our data collection process, however it does identify your Internet Service Provider.

You can configure your access to the Platform to refuse cookies. If you do so, you may not be able to use all or part of the Platform.

Analytics and Anonymisation

We may use Google Analytics, a web analytics service provided by Google, Inc. (Google). Google Analytics uses cookies (see above), to help us analyse how users use the Platform. Although Google Analytics records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you with us.

The information generated by the cookie about your use of the Platform will be transmitted to and stored by Google on servers in your country of residence. Google will use the information on behalf of us for the purpose of evaluating your use of the Platform, compiling reports on activity for us and providing us with other services relating to activity and internet usage. The IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of these cookies. You can also opt out of being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: http://tools.google.com/dlpage/gaoptout?hl+en

We also use Mixpanel, a product analytics service provided by Mixpanel, Inc., to understand how the Simma web app, apps and AI Assistant connector are used. Mixpanel receives your Simma account identifier, your name and email address, your self-rated ability levels, training thresholds and pool settings, whether a Garmin account is connected, the IP address of the device you signed in from (which Mixpanel uses to estimate an approximate location), and events describing what happened in your account — for example that an activity was processed (with its type, distance and duration) or that a connector function was called (with its name and outcome, never its inputs or results). Mixpanel stores this information on its servers in the United States. When your account is deleted, we ask Mixpanel to delete your profile.

We may use other data analytics tools as permitted by Australian law from time to time.

The purposes for which we collect, hold, use and disclose personal information

We collect, hold, use and disclose personal information for a variety of business purposes including:

• to provide the products or services you have requested from us;
• to compute training load, readiness and performance analytics and make them available to you and to the coach or squad you have chosen to share your data with;
• to improve our business, products and services;
• to promote our business to you;
• to market our other services or products to you;
• to handle and respond to your enquiries, complaints or concerns; and
• to provide personal information to third parties as set out in this Privacy Policy.

We may use Sensitive Information for the purpose of providing you with our services. We only use your Sensitive Information for other purposes if:

• You have consented;
• You would reasonably expect your information to be used for that purpose;
• A failure in disclosing the information would result in a serious risk to life, health or safety; or
• Your information is required or authorised by law to be disclosed.

Direct marketing

We also collect, hold, use and disclose your personal information to:

• notify you about the details of new services and products offered by us;
• send you our newsletters and other marketing publications;
• administer our databases for client service, marketing and financial accounting purposes; and
• to comply with our legal requirements regarding the collection and retention of information concerning the products and services that we provide.

If you do not wish to disclose your personal information for the purpose of direct marketing or you would like to opt-out of receiving direct marketing communications, you can do so by contacting us using the contact details set out below, or by following the instructions to unsubscribe which are contained in a communication that you receive from us.

Third Party Service Providers

We may disclose your personal information to third parties who work with us in our business to promote, market or improve the services that we provide, including:

• cloud hosting and data storage providers;
• device and wearable data platforms (for example Garmin, Apple);
• AI assistant providers, where a coach enables an integration (see AI assistant integrations below);
• providers of customer relations management database services and marketing database services;
• marketing consultants, promotion companies and website hosts;
• partnered businesses; and
• consultants and professional advisers.

We may also combine your personal information with information available from other sources, including the entities mentioned above, to help us provide better services to you.

Where we do share information with third parties, we require that there are contracts in place that only allow use and disclosure of personal information to provide the service and that protect your personal information in accordance with Australian law. Otherwise, we will disclose personal information to others if you've given us permission, or if the disclosure relates to the main purpose for which we collected the information and you would reasonably expect us to do so.

AI assistant integrations (Simma connector)

Simma offers a connector that allows coaches and athletes to work with their Simma data from within a third party AI assistant (each an AI Assistant). The connector currently supports Claude (provided by Anthropic) and Antigravity (provided by Google). Support for ChatGPT (provided by OpenAI) and Gemini (provided by Google) is being added, and we will update this policy when it is available and as we add others. The same connection is used by coaches and athletes. When a person signs in, Simma identifies which account they hold and makes available only the functions that apply to that account. This section explains how data is handled when a coach or an athlete uses the connector.

What the connector can access

When a coach connects Simma to an AI Assistant, the connector can return, for that coach’s own athletes only:

• athlete roster information (names and connection details);
• training session data and computed training metrics;
• physiological and readiness indicators derived from wearable data, presented against each athlete’s own baselines;
• athlete profile information, including training thresholds, ability by sport, units, pool length, body mass and any linked training plan;
• training load history and plan compliance information;
• training goals and the coach’s own private notes on the athlete; and
• the coach’s own message history with that athlete, and the coach’s own Simma profile and voice settings.

When an athlete connects Simma to an AI Assistant, the connector can return information about that athlete’s own training only: their profile and settings, training status and coaching context, activities, goals, the messages their coach has sent them, the coaches they are connected to and any linked training plan. An athlete’s coaching context is built without their coach’s private notes, which are never returned to the athlete.

The connector cannot return data about any athlete who is not connected to the requesting coach, and cannot return another person’s data to an athlete. Every request is made using the signed-in person’s own Simma credentials and is subject to the same access checks as the Simma web app.

Every athlete on Simma is attached to a coach. An athlete who has not joined a coach of their own is attached to a coach account operated by Simma. That account can read the athlete’s training data in the same way any coach can, including through the connector. Having no coach of your own does not mean that nobody can see your training data.

What the connector can do

The connector has functions that read data and functions that change it. Through the connector, a person can create, modify and delete data in Simma, and can send messages. Specifically:

• A coach can change an athlete’s settings (training thresholds, units, pool length and body mass), write, update and remove their private coaching notes on an athlete, create, update and delete an athlete’s goals, link or unlink an athlete’s training plan, edit their own coach profile and voice settings, and save, discard and send message drafts to their athletes.
• An athlete can change their own settings, create, update and delete their own goals, link or unlink their own training plan, and send a message to their coach.

Sending a message delivers a real email to the recipient immediately. It cannot be recalled. A message a coach sends arrives under the coach’s name, and the athlete has no way to tell it was written with an AI Assistant. Every send requires explicit confirmation by the person before it goes. For a coach, the AI Assistant must repeat the exact subject line and body of the stored draft back to Simma before we will send it, so a mistaken reference cannot send a different message than the one the coach approved; and where the AI Assistant supports it, the coach is also asked directly to confirm the send, and it stops if they decline or if that confirmation cannot be shown. An athlete’s message to their coach is confirmed with the athlete in the same way. Messages are always sent by Simma, from the sender’s Simma account, and are recorded in the message history in the same way as a message sent from the Simma web app.

Nothing an athlete does through the connector reaches anyone else, except a message they deliberately send to their coach after confirming it. The connector cannot create or delete athlete accounts, training sessions or wearable data, cannot change account or billing settings, and cannot message anyone other than a coach and athlete who are connected to each other in Simma.

How access is authorised

The person authorises the connection themselves by signing in with their own Simma account, and where the AI Assistant supports it this is done through an industry-standard authorisation flow (OAuth) in which the person explicitly approves the connection. The connector holds no privileged access of its own. It can only ever reach data that the signed-in person is already authorised to see and change in Simma: for a coach, the data of athletes who have joined that coach and consented to share their data with them; for an athlete, their own data. Connecting an AI Assistant does not expand anyone’s access to data.

Who sees the data

When a person asks their AI Assistant a question, the AI Assistant may request data from Simma through the connector. Data returned by the connector is transmitted to the AI Assistant provider (for example Anthropic, OpenAI or Google) in order to generate a response for that person. That processing is performed by the AI provider under its own terms of service and privacy policy, which the person agrees to separately when using that AI Assistant. We encourage everyone to review their AI provider’s data handling terms, including any settings relating to data retention and model training, before connecting Simma.

Simma does not see, receive or store the person’s conversation with the AI Assistant. We only see the requests the AI Assistant makes to our connector.

What we log and how long we keep it

For security, support and service improvement, we log connector activity. For each request we record the HTTP method and path, the response status and how long the request took, which connector function was called, the names of the parameters it was called with, the Simma account that made the request, and which AI Assistant product made it. We do not record the values of those parameters, the data the function returned, or any draft, note or training data involved, and we never see the conversation with the AI Assistant. We also send a record of each connector call to Mixpanel, our product analytics provider (see Analytics and Anonymisation above): the function name, whether it succeeded, how long it took, the account and the AI Assistant product, and nothing from the request or the response. Connector activity logs are retained for 12 months and then deleted or de-identified. The data returned in response to a connector request is generated on demand from information we already hold and is not separately retained. Where a person changes data or saves or sends a message through the connector, that change or message is stored in Simma in the same way as if it had been made in the Simma web app, and retained as described under Data retention below.

Your controls

• A person may disconnect an AI Assistant at any time by removing the connector in that AI Assistant’s settings, which prevents further data access through that connection. The connector also provides a sign-out link that clears the Simma sign-in session in the browser. Every time a connection is made again, the person is asked to sign in to Simma again.
• An athlete may at any time stop sharing data with a coach or disconnect their wearable, which also removes that data from what the coach’s connector can access going forward.
• Access and correction requests can be made as described in How we handle requests to access your personal information below.

Coaches’ and athletes’ responsibilities

Coaches who use the connector do so as part of providing coaching services to their athletes. Coaches must only use the connector in respect of athletes who have consented to share their data with them through Simma, and should inform their athletes that they use AI-assisted tools to review training data. Athletes who use the connector do so for their own training only. Insights generated by an AI Assistant from Simma data are produced by the AI provider, are not medical advice, and should be applied with the coach’s professional judgement or, for an athlete, their own judgement. A person remains responsible for any change made to Simma data and for the content of any message drafted with an AI Assistant, and should read a message in full before approving it to be sent.

Overseas disclosure

Some of the third parties we use to provide our services store or process information outside Australia, including:

• cloud hosting and storage providers located in the United States;
• wearable and device platform providers (for example Garmin, Apple); and
• where a coach chooses to use an AI Assistant integration, the relevant AI provider (for example Anthropic or OpenAI), located in the United States.

Where we disclose personal information overseas, we take reasonable steps to ensure the recipient handles it in a manner consistent with the Australian Privacy Principles, including through contractual protections where appropriate. Where a coach directs data to an AI Assistant through the connector, that disclosure occurs at the coach’s request and is governed by the AI provider’s terms as described above.

Data retention

We retain personal information for as long as needed to provide our services and as required by law. In particular:

• account information is retained while an account remains active and for 12 months after closure;
• training, wearable and competition data is retained while the relevant athlete account remains active, so that longitudinal analysis remains possible, and is deleted or de-identified within 12 months of account closure or a verified deletion request;
• connector activity logs are retained for 12 months; and
• information we must keep to comply with legal obligations (for example financial records) is retained for the period required by law.

You may request deletion of your personal information at any time using the contact details below. We will action verified requests within a reasonable period, except where we are required or permitted by law to retain the information.

Athletes under 18

Simma is used by squads that may include athletes under 18. Where an athlete is under 18, a parent or guardian must consent to the collection and handling of the athlete’s personal information, including their training and health data, and to its sharing with the athlete’s coach. Parents and guardians may exercise any of the rights in this policy (including access, correction and deletion) on behalf of the athlete.

How we handle requests to access your personal information

You have a right to request access to your personal information which we hold about you and to request its correction. You can make such a request by contacting us using the contact details set out in this policy.

We will respond to any such request for access as soon as reasonably practicable. Where access is to be given, we will provide you with a copy or details of your personal information in the manner requested by you where it is reasonable and practicable to do so.

We will not charge you a fee for making a request to access your personal information. However, we may charge you a reasonable fee for giving you access to your personal information.

In some cases, we may refuse to give you access to the information you have requested or only give you access to certain information. If we do this, we will provide you with a written statement setting out our reasons for refusal, except where it would be unreasonable to do so.

How we handle requests to correct your personal information

We will take such steps (if any) as are reasonable in the circumstances to make sure that the personal information we collect, use or disclose is accurate, complete, up to date and relevant.

If you believe the personal information we hold about you is inaccurate, irrelevant, out of date or incomplete, you can ask us to update or correct it. To do so, please contact us using the contact details listed below.

How to contact us or make a complaint

If you have any questions about this Privacy Policy, if you wish to correct or update information we hold about you or if you wish to request access or correction of your personal information or Sensitive Information or make a complaint about a breach by us of our privacy obligations (including the way we have collected, disclosed or used your personal information or Sensitive Information), please contact:

coaching@getsimma.com

We will acknowledge and investigate any complaint about the way we manage personal information and Sensitive Information as soon as practicable. We will take reasonable steps to remedy any failure to comply with our privacy obligations.