Privacy Policy

Last updated: 14. Aug. 2026

Protocol 60 spans three things: this website, a private coaching practice, and an iOS app. Each handles data differently, so this policy is split into those three scopes. I'm Robert Turrall, trading as turrall & co., Baarerstrasse 77, 6300 Zug, Switzerland. Swiss data protection law (nFADP) applies, aligned with the EU GDPR. For any privacy question, contact privacy@protocol60.com.

1 · Website (protocol60.com)

Hosting. This site is hosted by cyon GmbH, in Switzerland. Standard server logs (IP address, timestamp, requested URL, user agent) may be processed transiently for security and delivery.

Analytics. I use Plausible, a privacy-focused, EU-hosted analytics service that sets no cookies and builds no personal profiles — which is why this site needs no cookie banner. I see aggregate traffic only — page views, referrers, countries — never individuals.

Newsletter/Blog. My newsletter and blog are published via Substack. If you subscribe, your email address and activity are handled under Substack's privacy policy.

Forms. The early-access application form is self-hosted on my own server at cyon GmbH in Switzerland — there is no third-party form processor. The details you submit (name, email, and your answers) are sent by that server to my own mailbox at contact@protocol60.com so I can respond, and are not shared with anyone else. The form sets no tracking cookies.

Affiliate links. Some outbound links on this site may be affiliate links, disclosed inline wherever they appear (see my gear page). If you follow one, the destination site may set its own cookies under its own policy — I set none on their behalf, and I receive no personal data about you from these programmes beyond aggregate referral counts.

2 · Coaching

If you engage Protocol 60 for private coaching, I process personal data — including health data — for the sole purpose of delivering that coaching. This is detailed in Annex 1 of the coaching agreement, a copy of which may be provided upon request to privacy@protocol60.com.

In short:

Categories of data: intake questionnaire responses, health-screening answers, wearable data exports (e.g. WHOOP or Apple Watch — HRV, resting heart rate, sleep, recovery), training logs, and correspondence. Where you choose to share it, recent bloodwork read alongside your physician's guidance.

Purpose & legal basis: delivery of the coaching service you have engaged, on the basis of your explicit consent for health data and the performance of our agreement for the remainder. You may withdraw consent at any time; this ends the coaching relationship for practical reasons.

Processors I use:

• Calendly — discovery-call and session booking.
• Zoom — video calls for discovery calls and ongoing coaching sessions.
• Proton Drive and encrypted local file storage — storage of coaching records (including questionnaires, health-related data, training logs, coaching notes and supporting documents).
• cyon GmbH, in Switzerland — email hosting, the same provider that hosts this site. Coaching correspondence is received and stored in my mailbox there.

Retention: coaching records are kept for 5 years after the end of the engagement, then deleted, unless a longer period is required by law. Form-check videos are deleted after review unless you request that they be retained, and invoices and accounting records are retained for 10 years in accordance with applicable legal requirements.

Your rights: under the FADP and GDPR you may request access, correction, deletion, restriction, and portability of your data, and you may lodge a complaint with a supervisory authority. Contact privacy@protocol60.com.

3 · iOS app

The app is built so your personal and health data never leaves your device. This is the app's genuine privacy advantage, and I state it plainly.

• All data is local. Health metrics read from Apple Health (HRV, resting heart rate, sleep, steps, SpO₂, VO₂ max, body weight), your protocol (supplements, habits, medications) and completion records, and your app preferences are all stored on your iPhone using Apple's on-device frameworks (CoreData and CareKit). None of it is transmitted to Protocol 60 servers.
• The WHOOP OAuth proxy is stateless. If you connect WHOOP, an authentication code is briefly exchanged by my proxy at api.protocol60.com, hosted in the EU (Hetzner, Germany). It stores no user data and no tokens — it performs the token exchange and returns the result to your device. WHOOP's own handling is governed by WHOOP's privacy policy.
• Apple Health. The app reads only the data types it displays, with your explicit permission, and does not write to Apple Health. Review or revoke access anytime in Settings → Privacy & Security → Health → Protocol 60.
• Backups. If you have iCloud device backup enabled, this data may be included in your device backup, governed by Apple's privacy policy.
• I do not require accounts, run analytics SDKs, display advertising, or sell or share your data. Deleting the app permanently removes all of its data from your device.

Changes to this policy

I may update this policy as Protocol 60 evolves. Material changes will be reflected in the "Last updated" date above, and, for the app, noted in release notes.