SECTION 01 — DATA
The personal data we collect, itemised.
- AccountYour Apple sign-in identifier, the email Apple releases to us (a private relay address if you use Hide My Email), display name, and an optional username and avatar.
- ProfileTime zone, language, height, age, sex, units, goal, dietary preferences and allergens, training experience, onboarding answers.
- HealthBody measurements; progress and body-scan photographs; meals and their nutrition; supplements; workouts, sets, reps, weights and RPE; blood-test documents and parsed markers; wearable metrics.
- MessagesYour AI coach conversations, and anything you send our support or privacy addresses.
- DeviceApp version, OS version, device model, language and region, and your IP address in transit.
- SubscriptionApple's anonymous transaction identifier, the product, and renewal status. We never receive card details.
SECTION 02 — PURPOSES
Why we process it.
To create and secure your account; to provide the features you use — dashboards, trends, nutrition targets, AI coaching, bloodwork explanations, physique scoring; to send reminders you asked for; to manage your subscription; to keep the service secure; and, where you separately agreed, to understand how the app is used so we can improve it.
SECTION 03 — GROUNDS
On what ground.
Section 4 of the Act permits exactly two grounds, and we use both.
- ConsentSection 6 — for sending your data to our AI provider, for connecting a wearable, and for notifications. The AI consent is asked specifically and at the point of use: before your first scan is sent for analysis, on its own screen, and refusing keeps the rest of the app working. None is bundled into our Terms.
- Legitimate useSection 7(a) — the specified purpose for which you voluntarily gave us your data. Covers operating your account and the core logging the app exists to do: the measurements, meals, supplements and workouts you type in yourself, so you can see them tracked. We don't ask you to consent to that separately, because you give it to us for that purpose and we use it for nothing else. The same ground covers progress photos, body scans and bloodwork you choose to upload — optional features that collect nothing unless you use them — and product analytics, which run by default and which you can switch off any time.
● NOT LEGITIMATE INTERESTS
We do not rely on "legitimate interests". No such ground exists in Indian law, and nothing in this service depends on one.
SECTION 04 — SHARING
Who receives it.
Processors engaged under written contract: Supabase, Inc. (database, authentication, storage), OpenAI OpCo, LLC (AI inference), Apple Inc. (sign-in, payments, push, HealthKit), PostHog, Inc. (product analytics, on by default and switchable off — receives no health data), AppsFlyer Ltd. and RevenueCat, Inc. (advertising measurement and subscriptions — neither receives health data), and any wearable provider you connect.
Data is processed in the United States. India has notified no restricted countries under Section 16, so this transfer is permitted; we apply contractual and technical safeguards regardless.
SECTION 05 — RETENTION
How long we keep it.
For the life of your account. Items you delete go within 30 days. Deleting your account removes your data within 30 days — except subscription records, kept seven years for tax and audit, and support correspondence, kept three years.
SECTION 06 — RIGHTS
Your rights, and how to use them.
- AccessSection 11 — a summary of your data, who holds it, what has been shared. Settings › Privacy › Export my data.
- CorrectSection 12 — edit entries directly in the app. Settings › Privacy › Delete Account erases everything.
- GrievanceSection 13 — email [email protected]. We respond within 90 days, in practice far sooner. You must use this before approaching the Board.
- NominateSection 14 — nominate someone to exercise your rights if you die or become incapacitated. Email us to record a nominee.
- WithdrawSection 6(4) — Settings › Privacy has a switch for AI features and one for analytics; notifications live in Settings › Notifications and a wearable is disconnected from Settings › Integrations. One tap, exactly as easy as granting was, effective immediately on our servers as well as your device — switching off AI features stops our servers sending anything to the AI provider, not just the app.
SECTION 07 — THE BOARD
Complaining to the Data Protection Board.
If our grievance process has not resolved your concern, you may complain to the Data Protection Board of India. You must exhaust our process first (Section 13). Details are published by the Ministry of Electronics and Information Technology at meity.gov.in.
SECTION 08 — CHILDREN
Under 18.
The minimum age to register in India is 18, because the Act treats anyone under 18 as a child (Section 2(f)). We do not knowingly process a child's personal data, and we do not carry out tracking, behavioural monitoring, or targeted advertising directed at children.
SECTION 09 — LANGUAGES
Want this in another language?
This notice is published in English. Under Rule 3(3) you can ask us for it in any of the 22 languages in the Eighth Schedule to the Constitution of India — Assamese, Bengali, Bodo, Dogri, Gujarati, Hindi, Kannada, Kashmiri, Konkani, Maithili, Malayalam, Manipuri, Marathi, Nepali, Odia, Punjabi, Sanskrit, Santali, Sindhi, Tamil, Telugu or Urdu.
Email [email protected] with the subject "Notice in [language]" and we'll send it over within 30 days. No charge, and you don't need to give a reason.
[email protected] · Alwyn Ventures, C-11/254, 2nd Floor, Sector 3, Rohini, Delhi, India – 110085