Privacy Policy
Axon Perform Ltd (NZBN 9429053275806) ("Axon", "we", "us", or "our") provides a sports performance intelligence platform to professional and elite sports organisations. This Privacy Policy explains how we collect, hold, use, disclose and protect personal information across our website, the Axon HQ web platform, the Axon Pulse mobile app, and our associated APIs and services (together, the "Services").
We comply with the New Zealand Privacy Act 2020, the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018, the EU General Data Protection Regulation (EU GDPR), and the California Consumer Privacy Act (CCPA) where applicable.
1. How our Services are structured
The Axon platform is sold to sports organisations (clubs, national governing bodies, and academies). Where you are an athlete or staff member using Axon through your club:
Your club is the data controller. They determine what data is collected about you and why.
Axon is the data processor. We process that data on the club's instructions under a Data Processing Agreement.
Sahha is a sub-processor we use for health and wellness data on the Axon Pulse mobile app (see Section 6).
If you have questions about why your data was collected or want to exercise your rights as a data subject, contact your club in the first instance. We will assist your club in responding.
Where you interact with us directly (website visitor, prospective customer, job applicant), Axon is the controller for that personal information.
2. The information we collect
Information you or your club provides
Identifiers: name, email address, club, role, jersey number, date of birth
Authentication: hashed password, sign-in tokens
Contact details where relevant
Athlete profile information your club uploads (position, squad, contract dates)
Health, fitness, and wellness data (Axon Pulse mobile app)
Wellness check-in responses (sleep, soreness, mood, stress, fatigue ratings)
Wearable and health data collected through your device, including data from Apple HealthKit (iOS) and Health Connect (Android), Garmin, WHOOP, Apple Health, and other connected sources
Training load, recovery scores, and biometric measurements derived from the above
Activity and motion data from your device sensors
This data is processed through our health-data sub-processor, Sahha (sahha.ai). See Section 6.
Performance and training data
GPS and tracking data from your club's integrations (Catapult, STATSports, etc.)
Force-plate and gym data (VALD, GymAware, OVAL, WattBike, Teambuildr)
Match and event data (Opta, Wyscout)
Medical and availability information your club records about you
Technical information
Device type, operating system, app version, IP address, time zone
Crash logs and diagnostic information
Service usage events (which features were used, when)
Cookies and similar technologies (website only)
Our website uses cookies for essential functionality, analytics, and remarketing. See Section 10.
3. How we use personal information
We use personal information to:
Provide the Services to your club and to you as their athlete or staff member
Authenticate you and keep your account secure
Sync, store, and process health and performance data on your club's behalf
Generate reports, analyses, and AI-assisted insights for your club's performance staff
Communicate with you about the Services (account notifications, security, support)
Operate, maintain, secure, and improve the Services
Comply with our legal obligations and respond to lawful requests
Where we are the controller (website, sales enquiries), to market the Services to prospective customers
Legal bases for processing (UK / EU GDPR)
Where we process personal data of UK or EU data subjects, we rely on the following legal bases:
Contract (Article 6(1)(b)): processing necessary to deliver the Services your club has contracted us to provide
Legitimate interests (Article 6(1)(f)): security, fraud prevention, product improvement, direct marketing of B2B Services
Consent (Article 6(1)(a)): where required, for example marketing communications to individuals and any non-essential cookies
Legal obligation (Article 6(1)(c)): tax, accounting, and legal compliance
For health data (special category personal data under Article 9), processing is on the basis of your explicit consent to the relevant device permissions (HealthKit, Health Connect, wearable connections) and your continued use of the Axon Pulse app, supported by employment context where applicable under Article 9(2)(b).
4. Who we share personal information with
We share personal information with:
Your club: all athlete and performance data is accessible to authorised staff at your club. Your club determines who within their organisation has access.
Our sub-processors: third parties who process personal information on our behalf under contract:
Sahha (sahha.ai/privacy): health and wellness data integration on the Axon Pulse app
Snowflake: cloud data warehousing
Amazon Web Services and Microsoft Azure: cloud hosting and infrastructure
Google Analytics: product and website analytics
Apple Push Notification service and Firebase Cloud Messaging: push notifications
Our team: employees and contractors who need access to perform their role, under confidentiality obligations
Professional advisors: lawyers, accountants, and auditors where engaged
Acquirers: in the event of a sale, merger, or restructure of our business, with notice to affected parties
Authorities: where required by law, court order, or to protect rights and safety
We do not sell personal information. We do not share personal information with advertisers for the purpose of cross-context behavioural advertising.
A current list of sub-processors is available on request from privacy@axonperform.com.
5. International transfers
Axon is headquartered in New Zealand. Our infrastructure runs primarily in cloud regions in Australia, the United States, and the European Union. Personal information is transferred between these regions as part of normal Service operation.
Where we transfer personal data out of the United Kingdom or European Economic Area, we rely on:
Adequacy decisions where available (the UK has recognised New Zealand as adequate)
Standard Contractual Clauses (the UK International Data Transfer Addendum and the EU SCCs) with appropriate safeguards
Your explicit consent in limited circumstances
A copy of the transfer mechanism applicable to you is available on request.
6. Sahha and the Axon Pulse mobile app
The Axon Pulse mobile app uses Sahha (sahha.ai) as its health and wellness data integration layer. Sahha unifies wearable, health, and lifestyle data from Apple HealthKit, Health Connect, Garmin, WHOOP, and other connected sources.
How it works:
Axon Pulse passes Sahha an opaque external user ID for you. Sahha does not receive your name, email, or other directly identifying information.
Sahha processes the health and wellness data your device shares with the app and returns biomarkers, scores, and archetypes to Axon.
Sahha is a sub-processor for Axon under a written agreement that requires Sahha to meet equivalent data protection standards.
Sahha's privacy policy: sahha.ai/privacy.
Health Connect (Android): the Axon Pulse Android app's Health Connect integration is governed by this Privacy Policy, declared in the Android manifest as required by Google.
7. Retention
We retain personal information for as long as your club uses the Services and for a defined period afterwards in accordance with the Data Processing Agreement with your club. Default retention is:
Active accounts: for the duration of your club's subscription to Axon
After account closure or deletion: identifiers and profile data deleted within 30 days, except where retention is required for legal, accounting, or audit purposes (typically up to 7 years)
Backups: rolling backups may retain data for up to 90 days after deletion, after which the data is overwritten
Anonymised and aggregated data: may be retained indefinitely for product improvement and benchmarking, with no link to you
Specific retention periods agreed with your club override these defaults.
8. Your rights
Your rights depend on the law that applies to you. In all cases, contact your club first if your data was collected through the Services. Axon will assist your club in responding to your request.
All users
You may:
Request access to the personal information we hold about you
Request correction of inaccurate information
Request deletion of your account and associated data (see Section 9)
Object to marketing communications and unsubscribe at any time
Make a complaint to us at privacy@axonperform.com
UK and EU data subjects (UK GDPR / EU GDPR)
In addition, you have the right to:
Restrict processing in certain circumstances
Data portability: receive your data in a structured, machine-readable format
Object to processing based on legitimate interests
Withdraw consent where consent is the legal basis (does not affect prior lawful processing)
Not be subject to fully automated decisions that produce legal or similarly significant effects
Lodge a complaint with your supervisory authority (UK: the Information Commissioner's Office, ico.org.uk; EU: your national DPA)
California residents (CCPA)
In addition, you have the right to:
Know what personal information we collect and how it is used
Request deletion of your personal information
Opt out of the "sale" or "sharing" of personal information (Axon does not sell or share personal information as defined by the CCPA)
Non-discrimination for exercising your rights
To exercise CCPA rights, email privacy@axonperform.com with "CCPA Request" in the subject line.
New Zealand residents (Privacy Act 2020)
Your rights under Information Privacy Principles 6 and 7 (access and correction) apply. Contact privacy@axonperform.com or your club.
9. Account deletion
Athletes using the Axon Pulse mobile app can request account deletion directly inside the app: Settings > Account > Delete Account. Your club will be notified of the request. Once approved or after a defined period, your account and associated profile data are deleted from Axon and the deletion is propagated to Sahha.
Athletes can also request deletion at any time by emailing support@axonperform.com or visiting axonperform.com/delete-account.
Performance staff and other club users should request deletion through their club administrator.
Deletion does not remove anonymised performance data that has been incorporated into your club's aggregated reporting where the data no longer identifies you.
10. Cookies and tracking on our website
Our website (axonperform.com) uses cookies for essential site functionality, anonymous analytics, and remarketing on platforms including Google and LinkedIn. A cookie banner allows you to manage non-essential cookies. The Axon HQ web platform and Axon Pulse mobile app use only essential cookies and tokens required for authentication and Service delivery.
11. Security
We use industry-standard technical and organisational measures to protect personal information, including:
TLS encryption for all data in transit
Encryption at rest in our cloud infrastructure
Role-based access controls and multi-factor authentication for staff
Regular access reviews, audit logging, and security testing
Sub-processor due diligence and contractual security obligations
No transmission over the internet is fully secure. While we take security seriously, you use the Services at your own risk.
12. Children and minors
The Axon Pulse mobile app is rated 17+ on the App Store and equivalent on Google Play. Axon Pulse is provisioned by clubs to authenticated athletes only. We do not knowingly collect personal information from anyone under 13.
Where athletes are under 18, the client club obtains parental or guardian consent as part of their athlete onboarding process. This is set out in the Data Processing Agreement between Axon and the club. If you believe a minor has provided us with personal information without appropriate consent, contact us at privacy@axonperform.com and we will investigate and act promptly.
13. Changes to this policy
We may update this Privacy Policy. Material changes will be notified through the Services or by email to your club administrator. The "Last updated" date at the top of this page indicates when the policy was last revised.
14. Contact
Privacy Officer
Axon Perform Ltd
NZBN 9429053275806
Email: privacy@axonperform.com
Support: support@axonperform.com