Privacy Policy

**FitnessFor** [ATTORNEY REVIEW REQUIRED: Insert legal entity name and address]

**Effective Date:** [ATTORNEY REVIEW REQUIRED] **Last Updated:** [ATTORNEY REVIEW REQUIRED]

1. Who We Are

[ATTORNEY REVIEW REQUIRED: Insert entity description, data controller identity under GDPR (if applicable), and contact details for privacy questions]

2. What Data We Collect

2a. Data You Provide

| Data | Purpose | Retention | |---|---|---| | Email address | Account identity, magic-link login, transactional email | Duration of account + [ATTORNEY REVIEW REQUIRED: post-deletion period] | | Name (first name only) | Personalized coaching | Duration of account | | Age, height, biological sex | Exercise ramp placement | Duration of account | | Weight (optional, body-comp users only) | Trend analysis — never displayed as a raw number in AI coaching | Duration of account or until user disables weigh-ins | | Injury / condition flags | Conservative exercise filtering (binary flags, no diagnosis) | Duration of account | | Exercise history and session logs | Plan adaptation, progress tracking | Duration of account | | Goal text (free-form) | AI goal classification — used to select programming matrix rows | Duration of account | | Habit snapshots (sleep, alcohol, smoking, sitting, hydration) | Weekly check-in context for AI coaching | Duration of account | | Futures ladder entries (user-written) | Motivational journaling — never shared | Duration of account | | Weekly check-in responses | Plan steering | Duration of account | | Coach's inbox messages (user-to-AI) | Contextual plan adjustments | Duration of account | | Legal acceptance timestamps and IP | Compliance audit log | [ATTORNEY REVIEW REQUIRED: statutory minimum retention] |

2b. Data Collected Automatically

| Data | Purpose | |---|---| | Device type and OS | Session player compatibility, push notification routing | | Expo push token | Push notifications (never sold or shared with advertisers) | | App version | Bug triage |

2c. Data We Do NOT Collect

Location data
Contact lists
Camera or microphone access (outside explicit user-initiated actions)
Browsing history
Financial data beyond subscription status (payments processed by Stripe / Apple / Google — we receive only subscription status, not card details)
Health data from HealthKit / Google Fit (not integrated)

3. Health Data — Special Handling

Injury flags, weight logs, habit data, and goal classifications are **health-related data** and are treated with heightened protection:

**No third-party advertising or analytics trackers receive health data.** Period.
Health data is not used to train third-party AI models. API calls to Anthropic are made with session-scoped context only; we do not transmit persistent user health profiles to Anthropic.
Health data is stored encrypted at rest in our PostgreSQL database hosted on [ATTORNEY REVIEW REQUIRED: hosting provider and region].
Health data is not sold, licensed, or rented to any third party.

[ATTORNEY REVIEW REQUIRED: Review against CCPA "sensitive personal information" definition, HIPAA applicability (confirm fitness app exclusion applies), and any applicable state biometric/health data laws — Illinois BIPA, Texas CUBI, Washington My Health MY Data Act]

4. How We Use Your Data

We use your data to: 1. Generate and adapt your exercise plan 2. Deliver AI coaching responses (Anthropic Claude — see Section 6) 3. Send transactional and coaching emails (Resend — see Section 6) 4. Process subscription billing (Stripe / Apple / Google — see Section 6) 5. Send push notifications you have opted into 6. Detect and fix bugs and service issues 7. Comply with legal obligations

We do **not** use your data for: - Targeted advertising - Selling to data brokers - Building advertising profiles - Cross-app tracking

5. Legal Bases for Processing

[ATTORNEY REVIEW REQUIRED: Required for GDPR compliance. List legal basis for each processing activity — contract performance, legitimate interest, consent. Include legitimate interest balancing test documentation in internal records]

6. Third-Party Processors

We share data only with the following processors under written data processing agreements:

| Processor | Purpose | Data shared | Link | |---|---|---|---| | **Anthropic** | AI coaching and goal classification | Session context (goals, recent activity, check-in data — no persistent health profile) | [ATTORNEY REVIEW REQUIRED: Anthropic DPA link] | | **Stripe** | Web subscription billing | Email, subscription status | [stripe.com/privacy](https://stripe.com/privacy) | | **Apple** | App Store billing and push notifications | Device token, subscription status | [apple.com/privacy](https://apple.com/privacy) | | **Google** | Play Store billing and push notifications | Device token, subscription status | [policies.google.com/privacy](https://policies.google.com/privacy) | | **Resend** | Transactional email | Email address, first name | [ATTORNEY REVIEW REQUIRED: Resend DPA link] | | **RevenueCat** | Subscription entitlement management | Subscription status only — no health data | [revenuecat.com/privacy](https://www.revenuecat.com/privacy/) | | **[ATTORNEY REVIEW REQUIRED: hosting provider]** | Database and API hosting | All data | [ATTORNEY REVIEW REQUIRED: DPA link] |

No other third parties receive your data.

7. Data Retention

**Active accounts:** Data retained for the duration of your subscription plus [ATTORNEY REVIEW REQUIRED: grace period].
**Deleted accounts:** Upon deletion request, we delete or anonymize personal data within [ATTORNEY REVIEW REQUIRED: timeframe — 30 days is a common standard] except where retention is required by law (e.g., legal acceptance audit logs, billing records).
**Legal acceptance logs:** Retained for [ATTORNEY REVIEW REQUIRED: statutory minimum, suggest 7 years] for compliance purposes.
**Backups:** Backup copies may persist for up to [ATTORNEY REVIEW REQUIRED: backup retention window] before full deletion.

8. Your Rights

Depending on where you live, you may have rights including:

**Access:** Request a copy of the data we hold about you.
**Correction:** Request correction of inaccurate data.
**Deletion ("Right to be forgotten"):** Request deletion of your account and associated data (see Section 9).
**Portability:** Request your data in a machine-readable format.
**Opt-out of sale/sharing:** We do not sell data, but you may submit this request.
**Restriction / objection:** Object to certain processing.

[ATTORNEY REVIEW REQUIRED: Map rights to applicable laws — GDPR Art. 15–22, CCPA/CPRA, UK GDPR, etc. Add response timeframes and verification process]

To exercise your rights: [ATTORNEY REVIEW REQUIRED: Insert contact method — email or in-app form]

9. Account Deletion (In-App)

You can delete your account from **Settings → Account → Delete Account** in the app. This initiates full data deletion as described in Section 7. Apple App Store requires this to be reachable in-app; this is that path.

[ATTORNEY REVIEW REQUIRED: Describe what happens to a coupled partner's account when one partner deletes — confirm spec decision and document here]

10. Children's Privacy

The App is intended for adults aged 18 and over. We do not knowingly collect data from anyone under 18. If you believe we have collected data from a minor, contact us at [ATTORNEY REVIEW REQUIRED: contact] and we will delete it promptly.

11. International Transfers

[ATTORNEY REVIEW REQUIRED: If you have users outside the US — describe transfer mechanisms (SCCs, adequacy decisions), hosting regions, and Anthropic API data routing]

12. Security

We use industry-standard safeguards including TLS in transit, encryption at rest, access controls, and regular security reviews. No system is perfectly secure; in the event of a data breach we will notify you as required by applicable law.

[ATTORNEY REVIEW REQUIRED: Insert specific certifications, audit schedule, and breach notification timeline per GDPR Art. 33 / state breach notification laws]

13. Changes to This Policy

Material changes will trigger an in-app re-acceptance prompt. We will not retroactively weaken privacy protections for data already collected without explicit consent.

14. Contact

Privacy questions, data requests, and deletion requests:

[ATTORNEY REVIEW REQUIRED: Insert privacy contact email, physical address, and Data Protection Officer contact if required under GDPR]

*This Privacy Policy was last reviewed by [ATTORNEY REVIEW REQUIRED: Attorney name and firm] on [ATTORNEY REVIEW REQUIRED: date].*