Privacy Policy

Effective date: October 19, 2025

Thank you for using Coachy AI: Fitness Tracker (the “App”). This Privacy Policy explains how Coachy AI: Fitness Tracker (“we”, “us”, “our”) collects, uses, shares, and safeguards your information when you use the App and related sites such as https://www.instagram.com/coachy.ai/ (collectively, the “Services”). It also describes your privacy rights and choices.

If you do not agree with this Policy, please do not use the Services. You can contact us at coachy.help@gmail.com with any questions.

1. Personal Data We Collect

We collect information (a) you provide, (b) that is created or collected automatically when you use the Services, and (c) from service providers and platforms you choose to connect.

A) Personal data that you provide

**General details.** Name or display name, email, age range, fitness goals, and optional attributes such as height/weight you enter during onboarding or later in your profile. Subscription tier and entitlement status are also associated with your account.
**Account photo (optional).** If you choose to upload a profile image.
**Communication information.** If you contact support, we process your email, any attachments, and the content of your messages.
**Nutrition entries.** Free-form meal descriptions and macro targets you input.
**Voice input & transcripts (optional).** If you dictate meals or notes, your audio is transcribed on-device via iOS Speech APIs; with your action, resulting text is processed by our App.
**Body analysis photos (optional).** If you request AI physique analysis, you can upload or capture front/side/back photos for analysis.

B) Data from Apple frameworks/services you authorize

**HealthKit data (with your consent).** For example, Active Energy (calories burned) and other metrics only if you explicitly grant access. **We do not use HealthKit data for advertising, marketing, or data brokerage.** You can manage permissions in Apple Health > Data Access & Devices.
**iCloud/CloudKit private database.** We store items like your profile, analysis results, and other content you choose to sync in your private CloudKit database tied to your Apple ID.

C) Data collected automatically

**Device & usage details.** Device model, OS version, app version, language/region, time zone, in-app events (e.g., screens viewed, feature toggles), and basic telemetry to operate and secure the Services.
**Purchase & subscription events.** We receive purchase status, product identifiers, and renewal state via Apple In-App Purchases and **RevenueCat**. We do **not** receive full payment card numbers from Apple.

D) AI processing inputs & outputs (your choice)

**Gemini requests.** When you use AI features—such as body analysis from photos or meal-text parsing—the App sends necessary inputs (text and, if you opt in, images) to **Google’s Generative AI (Gemini)** via HTTPS. We receive model outputs to display results. See §4 (Sharing) and §5 (Retention) for details. Before any photo is sent to an external AI service, faces are automatically censored on your device.

2. Purposes of Processing

We process personal data to:

**Provide and maintain the Services.** Core features like onboarding, profile, AI analysis, nutrition logging, rest timers/Live Activities, notifications, and sync.
**Personalize and improve.** Tailor plans and insights; debug, test, and develop new features; conduct product research using **aggregated or de-identified** data.
**Customer support and communications.** Respond to inquiries; send service notices, policy updates, and essential transactional messages.
**Subscriptions & entitlements.** Handle purchase validation, renewals, and access control via Apple IAP and RevenueCat.
**Safety, security, and fraud prevention.** Protect users, detect abuse, enforce policies, and secure the Services.
**Legal compliance.** Satisfy tax, accounting, and regulatory requirements.

Marketing. We do not use HealthKit data for marketing. If we ever send promotional communications, we will seek consent where required and you can opt out at any time (see §11).

3. Legal Bases (EEA/UK/Switzerland)

Where applicable law requires a legal basis, we rely on:

**Contract.** To provide the Services you request (e.g., creating your plan, enabling AI requests, managing purchases).
**Consent.** For HealthKit access, body photos and AI analysis, and certain notifications/marketing.
**Legitimate interests.** To keep the Services secure and reliable; to fix bugs, improve, and personalize non-sensitive features.
**Legal obligation.** To comply with laws (e.g., tax, accounting, consumer protection).

4. How We Share Information

We do not sell your personal information. We share data only as described below:

**Service providers (processors).** Under contracts limiting use to our instructions:
**Google (Gemini API).** Processes your chosen AI requests (text and optional photos) to provide results back to you. Face images are censored on device before any photo is transmitted for AI processing.
**Apple iCloud/CloudKit.** Stores your synced data privately to your Apple ID.
**Apple In-App Purchases & App Store.** Manages purchases, receipts, and refunds.
**RevenueCat.** Manages subscription entitlements.
**Diagnostics/telemetry providers (if enabled).** For crash reporting and performance; configured to avoid HealthKit uses.
**Legal reasons.** To comply with law or legal process; protect rights, safety, and security; prevent fraud or abuse.
**Business transfers.** In a merger, acquisition, or asset transfer, your information may transfer under this Policy.

HealthKit restriction. Health data obtained via HealthKit is not used for advertising, is not shared with data brokers, and is shared only as necessary to deliver features you choose and with your explicit consent.

iOS refunds. To help Apple adjudicate refund requests, we may share usage details related to the purchased content with Apple as permitted by App Store policies.

5. Data Retention

We retain data for as long as needed to provide the Services, comply with obligations, resolve disputes, and enforce agreements.

**Body analysis photos.** Used to generate your analysis; saved to your history only if you choose. You can delete them anytime in-app.
**AI request payloads and outputs.** Sent to Gemini to fulfill your request; retained by Google per their terms. We do not control Google’s independent retention.
**HealthKit.** Stored on-device and/or in your iCloud per your choices; you may revoke access and delete data via Apple Health.
**Purchases & entitlements.** Retained per legal and accounting requirements.
**Aggregated or de-identified data.** We may use de-identified data for research, analytics, and feature improvement; we will not attempt to re-identify it except as required by law.

6. Your Rights & Choices

Your rights vary by region and may include:

**Access, correction, deletion, portability.** Request copies, fix inaccuracies, delete, or export your data.
**Objection and restriction.** Object to or restrict certain processing.
**Consent withdrawal.** Where processing relies on consent (e.g., HealthKit, AI photos, marketing), you can withdraw it at any time. This will not affect prior lawful processing.
**Do Not Sell/Share (where applicable).** We do not sell personal information or share it for cross-context behavioral advertising.
**Supervisory authorities.** You may lodge a complaint with your local authority.

How to exercise. Many controls exist in iOS Settings (Health permissions, Photos, Camera, Microphone, Notifications) and in-app. You can delete your data at any time via Settings → Data & Deletion in the App (which can remove local data and your private iCloud database records for this App). Otherwise, email coachy.help@gmail.com. We may request information to verify your identity and will respond within the time required by law.

7. Security

We use technical and organizational measures to protect data, including encryption in transit, access controls, least-privilege practices, and platform security. No system is 100% secure. Please use device safeguards (e.g., strong passcode, latest OS updates).

8. Children

The Services are not directed to children under the age required by your jurisdiction (e.g., under 13 in the U.S.). Do not upload photos of minors. If you believe a child has provided data, contact us so we can take appropriate action.

9. Regional Disclosures (U.S. State Laws)

The categories of personal information we may process include:

**Identifiers** (e.g., name, email, device identifiers).
**Commercial information** (e.g., purchases, subscription history).
**Internet/network activity** (e.g., app interactions).
**Geolocation (coarse)** (e.g., country/state inferred from device settings/IP).
**Audio/visual information** (e.g., optional body photos, optional voice input transcripts).
**Inferences** (e.g., non-medical fitness preferences derived from your inputs).
**Sensitive data** (e.g., health data you authorize via HealthKit; photos you choose to upload). We use sensitive data only to provide the features you request and as otherwise permitted by law.

Cross-context behavioral advertising. We do not share personal information for cross-context behavioral advertising.

You can request additional details on sources, purposes, and disclosures by contacting coachy.help@gmail.com.

10. Cookies, SDKs, and Similar Technologies

If you visit our website https://www.instagram.com/coachy.ai/, cookies or similar technologies may be used for essential site operations and analytics. You can manage browser settings to limit cookies; some features may not function without them.

Health data is never used for advertising.

11. Your Choices About Our Communications

**Service messages.** You may receive transactional or service communications (e.g., subscription status, policy updates).
**Marketing.** If we send promotional communications, we will seek consent where required. You may opt out at any time (e.g., via in-app settings or by emailing **coachy.help@gmail.com**).
**Push notifications.** You can manage push permissions in iOS Settings.

12. International Data Transfers

Your information may be processed in countries with different data protection laws than your own. Where required, we implement appropriate safeguards (e.g., standard contractual clauses).

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated in-app or via other appropriate means. Your continued use after the effective date constitutes acceptance of the updated Policy.

14. Contact Us

Coachy AI: Fitness Tracker

Website: https://www.instagram.com/coachy.ai/

Email: coachy.help@gmail.com

If you have questions about this Policy or wish to exercise your rights, please contact us.