Privacy Notice

Last Updated: August 24, 2025

We are Nebula Sports, LLC ("Nebula", "we" or "us" and we care about our clubs, organizations, staff, and athletes' privacy. Throughout this Privacy Notice, we refer to the software, websites, mobile apps, and solutions offered by Nebula, and the content and features made available through our websites, mobile apps, and solutions collectively as the "Services."This Privacy Notice provides information about personal information we collect, use, and share when you interact with or use our Services.

Nebula defines personal information as any data that relates to an identifiable individual or that is linked or linkable to them. For example, information that directly identifies an individual like name is personal information. Also, data that does not directly identify you but that can reasonably be used to identify you such as IP address or device ID is considered personal information.

A little bit about us: we offer a membership-based performance and development platform ("Platform" designed for clubs, organizations, and staff ("Customers" who create accounts for their athletes and teams ("Users" to engage with Nebula through a mobile application ("App". We only collect personal information that is shared voluntarily. Customers can access insights about their teams and athletes via a dedicated web dashboard within the Platform. Users can register, take personality assessments, access reports about themselves, and reports about other athletes when linked. The Platform combines wearable data, self-reported inputs, and psychological insights from personality assessments into AI-powered reports that provide a holistic view of an athlete's physical and emotional state, along with personalized recommendations, and tools like progress tracking. Nebula's mission is to help teams foster stronger connections, enhance performance, and achieve collective success.

For avoidance of doubt, Nebula acts as a data processor also known as a service provider for our Customers and Users.

When you access or use our Services, you acknowledge that you have read this Notice and understand its contents. Your use of our Services and any dispute over privacy is subject to this Privacy Notice and our Terms of Use (including any applicable disclaimers of warranties, limitations on damages, and the resolution of disputes).

What Personal Information Do We Collect, How Do We Collect Personal Information, and Who We Share With?

Nebula collects personal information directly from our Customers when they purchase a membership, set up access, and provide athlete's contact information for the invites. After our Customer invites their athletes to the platform via email, the athlete may download the app from the appropriate app store and register in the app. The athlete registers with their email, name, and a password. Once logged in, the athlete can add for example their date of birth, their position on the team, the year they joined the team, height, and weight. For athletes who use wearables, the athlete may allow their wearable to share sleep data, training load/strain data and recovery data with Nebula. For athletes who do not use wearables, the athlete may manually input data via a journaling interface. The athlete also may complete a personality assessment. We combine the wearable and journaling data Athletes also have the option of linking their profiles with other athletes. Of course this is always done with their consent.

Our table below helps to describe the categories of personal information with examples, the sources, purpose, and categories of third parties with whom we share. Our specific third party service providers and how we share personal data with them is in section "When and What Personal Information Do We Disclose?"

Category Examples Source Purpose Third Parties We Share With
Identifiers Name, email address,IP addresses Website visitors, Customers, athletes when they create a membership for the organization and when individuals registers in the mobile app To provide the services as requested Service providers, the athlete’s organization, coach, and/or staff
Commercial information Payment method and type of membership purchased information Customers To provide the services as requested Service providers
Protected classification characteristics under California or federal law E.g. age of individuals over 40, gender identity or expression Athletes To provide the services as requested Service providers
Sensitive personal information E.g. personality assessment data such as communication style, motivational drive, conflict style, physiological and mental data
E.g. Total sleep hours and heart rate, mood, stress level
Customers, Athletes and their wearables To provide the services as requested Service providers, the athlete’s organization, coach, and/or staff, and athletes?
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). N/A N/A N/A N/A
Biometric information E.g. sleep. Health, or exercise data Athlete or the wearable device To provide the services as requested; provide scores on strain, recovery, wellbeing, sleep quality. Service providers
Internet or other electronic network activity information Browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement Website and mobile app To provide the services as requested Service providers
Geolocation data We do not collect precise geolocation data
Professional or employment- related information Certifications or training programs Coaches and staff To provide the services as requested Service providers, the athlete’s organization, coach, and/or staff
Personal Profile Data Date of birth, weight, height, playing position, dominant side, years with current club Athlete To provide the services as requested Service providers, the athlete’s organization, coach, and/or staff, and other athletes?
Inferences Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Athlete To provide the services as requested Service providers, the athlete’s organization, coach, and/or staff and with other athletes with consent

We may not collect each of the above categories of personal information from every individual who accesses or uses our Services.

We may also collect non-personal information from you when you use our Services. Non-personal information is information that does not identify or relate to a particular consumer or household, and includes information such as data collected through anonymous weekly check-ins or personal information that is de-identified or aggregated so that it is no longer identifiable.

How Do We Use Personal Information?

Nebula uses personal information in a variety of ways and for a variety of purposes, depending on how you interact with us, and depending on your role in interacting with us. For example, if you are a coach associated with an organization and have an administrator account, we use your personal information to administer your organization's account and to bill you for services, among other reasons. If you are an athlete, we use your information to provide you, and the account you are associated with, information about your strength, conditioning, and performance.

Nebula uses your information for the following purposes:

To provide you with Services as requested, including to ensure proper functioning of the services;

  • To create and administer your account;
  • To provide you with products or services you purchase or connect with via our Services;
  • To respond to your requests, communications, and inquires, including to send you updates and newsletters, as applicable;
  • To provide technical and customer support;
  • To comply with our legal obligations, and to enforce and defend Nebula's rights, and the rights of third parties, as we deem necessary;
  • To market to you, where we have the adequate consent (opt-out or opt-in) to do so;
  • To review and analyze the usage and operations of our Services, and to improve our offerings and Services;
  • To protect, detect, and investigate against fraudulent transactions or illegal activities in connection with our Services, including to maintain the integrity of our websites, mobile apps, and business;
  • For any other purpose we notify you of at the time of collection; and/or
  • For any other purpose you consent to, or direct us to.

We may not use all of your personal information for all the above purposes.

We rely on the following legal bases to process your personal information:

  • Performance of a contract for example between our Customer and Nebula and/or taking steps, at your request, to enter into such a contract.
  • Pursuant to your consent.
  • Compliance with a legal or statutory obligation.
  • Our legitimate interest. Our legitimate interests include but are not limited to: administering our Services; understanding our customers and users, and their needs; maintaining the security, integrity, and privacy of our Services; direct marketing to you; protecting the interests of our business; and communicating with customers and users. We will rely on this basis consistent with applicable data protection law\

Cookies, Analytics, and Tracking Technologies

Our Services utilize various cookies, tracking technologies, and analytics features. We use these tools for a variety of reasons, including to ensure the security, integrity, and proper functioning of our Services, to analyze and understand traffic to our Services from an analytics perspective, for our legitimate interests to provide you with Services, and to market our Services to you. Below describes some of the specific tools you may encounter while using our Services:

Analytics Providers

Analytics providers are third-party companies that collect information when people use our Services. These companies sometimes use cookies, web beacons, pixel tags, and similar technologies to keep track of what content or ads users view, how long they spend on different pages, how they arrived on a particular page (e.g., through a search query, link from another website, or a bookmark), and how they respond to the ads we show them. Subject to the other provisions of this Privacy Notice and your privacy choices, we may use analytics providers to analyze your information so that we can better understand our website visitors and their use of our Services.

Tracking Technologies

Subject to the other provisions of this Privacy Notice, our Services use cookies, clear GIFs, pixel tags, and similar tracking technologies, which we refer to collectively in this Statement as "cookies."

Cookies

Generally speaking, "cookies" are text files that are placed in your device's browser that can be used to help recognize your browser across different web pages, websites, and browsing sessions. Cookies are stored on your device or in "local storage." The HTML cookies that Nebula uses or has used, and some of the information that the cookies provide, are listed [TODO PLACE COOKIE REPORT LINK]. Your browser settings may enable you to manage whether you accept HTML cookies. We may use cookies or similar technologies in combination with personal information we collect from you through other methods to enhance and personalize your experience on our Services.

When and What Personal Information Do We Disclose?

Nebula will share personal information with service providers to support our Service. Nebula will use collected data to improve the platform's internal features, performance, and user experience. Aggregated and anonymized data may also be analyzed to identify trends in team behavior and performance. In some cases, Nebula may use anonymized reports for promotional purposes or to share insights with external organizations, e.g ( NWSL or NCAA leagues).

Name of Third Party Purpose Personal Data We Share Is it a “sale”or “sharing” under applicable law?
Whoop Wearable API If you give our app permission, we share an anonymized athlete in ID No
Apple HealthKit Wearable API If you give our app permission, we do not share anything. (it’s a localized system that works within the Apple ecosystem and captures data from the Watch without sharing any) Apple HealthKit does not sell or share health data, as it is strictly prohibited by its policies. For more information about Apple’s privacy practices, see Apple’s Health Privacy White Paper.
Brevo Email management Email and first and last name No
Stripe Payment Processor We share an anonymized coordinator ID and the user’s email No
OpenAI AI API tool used to create weekly report We share the athletes’ physiological and performance metrics in an anonymized report prompt No
Oura Wearable API N/A No
DigitalOcean Storage We store all information collected on our platform and app (for reference, all data is sent encrypted and we use secure protocols on every step) No
Google Analytics Website analytics We will share anonymized usage statistics and page tracking for performance measurement No, we implement the full suite of Google Analytics privacy controls

In addition to the above service providers, we also disclose, or may disclose, your personal information in the following circumstances:

  • In the event of a sale of our company, we may transfer your personal information or our rights in your personal information to an acquirer or other successor in interest.
  • When necessary, we disclose personal information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, by lawful request of public authorities and national security or law enforcement requirements, situations involving potential threats to the physical safety of any person, violations of Terms and Conditions, or as otherwise required by law. These disclosures may be to law enforcement or other enforcement bodies, or via valid judicial process (such as a third party subpoena)
  • If you otherwise direct us to disclose your information in a certain way, we will endeavor to fulfill your direction, unless it violates any of our policies, the rights of others, or the law.
  • We may also disclose your personal information for other specific or discrete purposes presented to you at the time of collection, or that you otherwise consent to.

Please note that in some instances, the use of your personal information by third parties may be also governed by that entity's Privacy Notice, in addition to or instead of this Notice.

What Rights and Choices Do You Have Regarding Your Personal

Information?

You have the following choices concerning how your personal information is collected or used:

  • Decline Cookies Using Your Browser Settings

    . You can configure your Internet browser to limit the placement of cookies and delete cookies, which may adversely affect some of the functionality of the Site and may not work on all websites, including ours.

  • Decline Cookies Using Our Preference Center

    . You can decline the placement of certain types of cookies using our preference center. Please note that while we do not discriminate against users for exercising choices regarding cookies, this may adversely affect some of the functionality of the website or Services (for example, some content may not load properly).

You also have the following rights with respect to your personal information. Please note that Nebula is considered a processor/service provider, as such, any requests made by Athletes or staff will be referred to the Organization/Club (Controller):

General Description of Right Description of How Website / App Users Take Advantage of the Right
Access or Disclosure: A right to request disclosure of your Personal Information, and to receive additional details regarding the Personal Information we collect and its use purposes, including any third parties with which we share information. This includes the right to know the categories of information we have collected about you in the last twelve months, as well as the categories of sources of personal information we have collected about you. Request this by contacting your organization directly or emailing us at [email protected]
Rectification/Correction: The right to correct inaccurate personal information and complete incomplete personal information. The Services allow you to edit your profile. If you need additional assistance, email your request to [email protected]
Erasure/Deletion: The right to deletion of personal information that we have collected, subject to certain exceptions. In some jurisdictions, this might include first “blocking” of the data. Request this by emailing us at [email protected].
Data Portability: In response to a request for disclosure, the right to receive your Personal Information in a readily useable format. Request this by emailing us at [email protected]. We will provide you with an export of your data in CSV format.
Objection to Processing and Sensitive Information: The right to object to processing for profiling, targeted advertising, cross-context behavioral advertising, and statistical, scientific, or historical research purposes. You also have the right to limit certain uses and disclosures of your sensitive personal information, to the extent we collect this information. Lastly, in some jurisdictions, you may oppose the processing of your data if there is a legitimate reason to believe the processing will harm you. Request this by emailing us at [email protected]. Set your cookie preferences to decline placing targeting cookies on your computer or device, although this may be of limited usefulness.  Unsubscribe to marketing emails from us.
Withdraw/Revoke Consent: Where the processing of personal information is based on consent, you have the right to withdraw your consent at any time. Withdraw your consent by emailing us at [email protected].
Opt Out of Sale or Share: The right to object to the “sale” or “sharing” of your personal information, as those terms are defined in relevant laws, subject to certain exceptions, and the right to know which categories of personal information we “sold” or “shared” about you in the last twelve (12) months. Nebula does not “Sell” or Share” your data as defined by law. You may make changes to your cookie and tracking preferences through our cookie banner
Appoint a Representative to Exercise your Rights (California): Under certain U.S. Privacy Laws, you may also designate an authorized agent to make these requests on your behalf. If you use an authorized agent to submit a request, we may need to collect additional information, such as a government issued ID, to verify your identity before processing your request to protect your information. Request this by emailing us at [email protected]
Right to Appeal: Some states have a right to appeal a business’s denial to act within a reasonable time. Nebula has established a process for such appeals. If the appeal is denied, we will inform consumers how they can submit a complaint to the attorney general. Request this by emailing us at [email protected]
File a Complaint with your Attorney General or the Relevant Supervisory Authority (EU and UK) A list of all relevant supervisory authority can be found at the European Commission’s Data Protection Authorities page

We do not discriminate against you if you exercise your privacy rights. We will not deny you goods or services; charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

When you make any of the above requests regarding your personal information, we will verify your request before endeavoring to fulfill it. We will require sufficient information from you in order to verify your request, and any information we collect through our verification procedures will be used only to verify the request.

If you would like to exercise any of the above rights, or if you have any questions about your rights, please contact us as described above or by using the information in the Contact Us section below.

Data Retention

The time period for which we retain your personal information depends on the purposes for which we collected it. Nebula will keep your personal information only for as long as we have a legitimate and lawful purpose to do so. The information we collect may be stored and processed in servers in the United States and wherever Nebula and our service providers have facilities around the globe. We will delete, destroy, or de-identify personal information when it is no longer necessary and we have no lawful basis to retain the information, consistent with Nebula's data retention practices and policies.

Data Security

We use reasonable technical, physical, and organizational measures to safeguard your personal information. While we take reasonable and appropriate measures towards data security, please keep in mind that no method of transmission via the internet, websites, or mobile apps is 100% secure and we cannot guarantee the security of your personal information. You can do your part to assist us in securing your personal information by changing your password at regular intervals, and by not sharing your login credentials with anyone else.

Information for EU and UK Residents

Nebula is based in the United States. Accordingly, if you are an EU or UK resident and access our Services, your personal data (referred to elsewhere in this Statement as "personal information" will be processed in the United States. The data protection and processing laws in the United States may offer a different level of protection than the laws in the jurisdiction in which you reside. Nebula utilizes standard contractual clauses where applicable as the mechanism for cross border transfers. Nebula may be required by law to disclose your personal data in certain circumstances, such as in response to inquiries or requests from government authorities, or to respond to judicial process in the United States. If we are compelled to provide information about you pursuant to judicial process, we will endeavor to provide you with notice of the request prior to supplying the information, where permitted by law. We rely on your consent to process personal data in the United States. If you do not want your personal data processed in the United States, please do not use Nebula's Services.

As noted above in the "What Choices Do You Have Regarding Your Personal Information?"section, we endeavor to provide EU and UK residents with rights afforded to data subjects in EU and UK jurisdictions regarding the processing of personal data. If you would like to exercise any rights you believe you have under applicable data protection law, including the rights specified in the section above, please contact us using the information in the Contact Us section of this StatementIf personal data covered in this Notice is to be used for a new purpose that is materially different from the purpose for which the personal data was originally collected or subsequently authorized, Nebula will provide you with an opportunity to choose whether to have your personal data so used or disclosed. To the extent required by the applicable law Nebula obtains opt-in consent for certain uses and disclosures of Sensitive Personal Data, if we collect this type of information and it is shared beyond what is allowable under the law.

Information for Australian Residents

When collecting, storing, using or disclosing Australian coach, staff, and athlete personal information, we are bound by the Privacy Act 1988 (Cth) (Privacy Act) (which incorporates the Australian Privacy Principles), the Sport Integrity Australia Act and the Sport Integrity Australia Regulations. We only collect your sensitive data and transfer your personal data out of Australia with your consent.

Children's Privacy

Nebula's websites do not knowingly collect information from children under sixteen (16) years of age. If you are under sixteen (16), do not send any information to us through our websites. In the event that we discover that a child under the age of sixteen (16) has provided personal information to us through our website without appropriate parental/guardian consent, we will immediately delete the child's personal information.

Nebula is committed to upholding and complying with its COPPA obligations, and in supporting schools in their compliance with FERPA. In furtherance of this, we participate in the iKeepSafe COPPA safe harbor program and are FERPA certified.

Data Storage and Data Transfers

Nebula is headquartered in the United States, but may use service providers throughout the world and store your information in other countries. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. As indicated above, we rely on standard contractual clauses to govern this transfer.

Our Services may contain links that you can click on to take you to other websites for your convenience and information. These websites may be operated by companies not affiliated with Nebula. Linked websites may have their own privacy notices and terms of use, which we strongly suggest you review if you visit those websites. We are not responsible for the content, privacy practices, or use of any websites that are not affiliated with Nebula.

Contact Us

If you have questions or concerns regarding this Privacy Notice or our privacy practices, or exercise your privacy rights, please contact us by emailing our team at [email protected] or emailing our Privacy Officer, [email protected],

If you are in the EU or UK, you may contact us by emailing us at [email protected] or emailing our Privacy Officer, [email protected]. Please note that if you do not contact us through our EU/UK Representative and you reach out to us directly, your email will be processed in the United States.

You may also contact an applicable regulator.

Changes to this Privacy Notice

We may update this Privacy Notice at any time as we deem appropriate. Where the changes are material, we will post them here in advance and, if the changes are likely to affect you personally, we will also attempt to contact you directly ( such as via email, if we have your email address). It is important that you check back from time to time and make sure that you have reviewed the most current version of this Privacy Notice. We will update the "last updated" date at the top of this Statement so that you are aware of when the last changes were made.

When there is a material change to this Privacy Notice, we will post a notice on this website and in our mobile app.