Privacy Policy

1. Information We Collect

We collect only what we need to run GainBuddy. Depending on the features you use, this includes:

Account information

• Email address, name, username, password (stored only as a salted bcrypt hash), date of birth, language and country.
• If you sign in with Apple or Google: the provider's account identifier and the email it shares (which may be a private relay address).
• Optional profile details: photo, bio, privacy setting.

Health and fitness information (sensitive)

• Sex, height, weight entries, target weight, activity level, training experience, injuries you choose to tell us about, and dietary preferences (for example kosher, vegetarian, allergies).
• Food and drink you log (including barcode scans and nutrition-label photos), calorie and macronutrient targets we calculate for you.
• Workouts, sets, repetitions, weights and personal records.
• Body and progress photos you choose to upload, and the estimates we derive from them (see section 14).

Community content

• Posts, photos, comments, kudos, follows, blocks and reports you make.

Purchases

• Subscription status, product, renewal dates and store (Apple App Store or Google Play) received from our subscription processor RevenueCat. We never receive your card number — payments are handled entirely by Apple or Google.

Device and usage information

• Device type, operating system, app version, a push-notification token, an app-generated device identifier (stored only as a keyed hash), and a keyed hash of your IP address at signup.
• Security logs (sign-ins, password changes, deletion requests) including IP address and user agent.
• Crash and error diagnostics with personal data removed.
• First-party product analytics: which onboarding steps you reach and a few key actions (app opened, food logged, workout finished, subscription screen viewed or started). Stored under a keyed pseudonymous hash with coarse labels only (never food, weights, photos or free text), kept for up to 400 days and deleted with your account. You can turn analytics off in Settings.

Referrals and support

• Which invite code you used and whether a referral reward was granted; messages you send to support.
• If you pair with an accountability partner, they see your logging streak and whether you logged or trained today (nothing else), and can send you one nudge a day. Either of you can end the pairing at any time.

We do not use advertising identifiers, we do not run third-party ad or analytics trackers in the app (our own analytics above stay on our servers), and we do not collect precise location.

2. How We Use Your Information

• To provide the service — calculate your calorie and macro targets, adapt them weekly from your weight trend and intake, generate and progress your training program, show your food log and history.
• Community features — show your posts to the audience you choose, deliver kudos, comments and follow requests.
• Rewards — compute streaks, XP, levels, badges and challenge progress.
• AI features you request — read nutrition labels from a photo, estimate body composition from body photos, suggest meals (section 16).
• Subscriptions and referrals — unlock paid features, apply trials and referral rewards, prevent referral fraud.
• Safety and security — protect accounts, prevent abuse and spam, moderate reported content, enforce our Terms, apply safety limits (for example calorie floors and no weight-loss deficits for users under 18).
• Communications — service emails (verification, password reset, receipts of important changes) and, if you allow it, push notifications. Marketing messages only with your opt-in.
• Legal compliance — respond to lawful requests and keep records we are required to keep.

3. How We Share Your Information

We do not sell your personal information and we do not share it for cross-context behavioral advertising. We never share health information with advertisers, data brokers or insurers.

We share data only:

• With other users, as you choose — your public profile (name, username, photo, level) and the posts you publish to their chosen audience. Private accounts are visible only to approved followers. Your food log, weight, targets and body analyses are never shared unless you post them.
• With service providers who process data on our behalf under contracts that restrict their use to providing services to us (section 7).
• For legal reasons — to comply with law or valid legal process, to protect the rights, safety and property of users or others, or in an emergency involving risk of serious harm.
• In a business transfer — if we are involved in a merger or acquisition, subject to this policy and with notice to you.

4. Data Security

We protect your data with encryption in transit (TLS 1.2+) and at rest, private photo storage served only through short-lived signed links, removal of location and other metadata (EXIF/GPS) from every uploaded image, hashed passwords and tokens, rotating sessions with theft detection, optional two-factor authentication, rate limiting, strict per-user access checks on every request, least-privilege staff access with audit logging, and regular dependency patching.

No system is perfectly secure. If we learn of a breach affecting your personal data we will notify you and the relevant authorities as required by law. See our Security page.

5. Data Retention

We keep your data while your account is active. When you delete your account:

• Your account is deactivated and hidden immediately, and all sessions are signed out.
• After a 30-day grace period (during which signing back in cancels the deletion) we permanently delete your profile, logs, photos, posts and all other personal data, and delete your record at our subscription processor.
• We keep a minimal, pseudonymised security and billing record (for example that an account was deleted on a date) for up to 24 months where needed for fraud prevention, legal claims or tax obligations. IP addresses in security logs are removed after 12 months.

You can delete individual photos, posts, logs and analyses at any time. Details are on our data deletion page.

6. Your Privacy Rights

Wherever you live, you can:

• Access and export your data — in the app (Settings → Privacy → Export my data) you get a machine-readable copy.
• Correct your profile and logs directly in the app.
• Delete your account and data in the app (Settings → Account → Delete account) or at /data-deletion.
• Withdraw consent for photo analysis, AI processing, health-data processing or marketing at any time in Settings, without affecting processing that happened before.
• Object or restrict certain processing, and complain to your data-protection authority.

Email privacy@gainbuddy.fit for any request. We respond within 30 days (or sooner where local law requires) and may need to verify your identity. You can use an authorised agent where the law allows. We will not discriminate against you for exercising your rights.

7. Third-Party Services

We use these processors. Each receives only the data needed for its function:

8. Children's Privacy

GainBuddy is not intended for anyone under 16. We ask for date of birth at signup and do not allow accounts for people under 16. If we learn we have collected data from someone under 16 we delete it. Parents or guardians who believe a child has an account can contact privacy@gainbuddy.fit.

Users aged 16–17 receive maintenance-only nutrition targets (no calorie deficit) and conservative defaults.

9. International Data Transfers

Our providers may process data in the United States, the European Union and other countries. When we transfer personal data from the EEA, UK, Switzerland or Israel to countries without an adequacy decision we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses (and the UK Addendum), together with supplementary measures such as encryption. You can request a copy of the relevant safeguards.

10. Updates to This Policy

We will post changes here and update the date above. For material changes we will notify you in the app or by email before they take effect, and ask for consent again where required.

11. California Privacy Rights (CCPA/CPRA)

California residents have the right to know what personal information we collect, use and disclose; to delete it; to correct it; to opt out of sale or sharing (we do neither); and to limit use of sensitive personal information (we use it only to provide the services you request, as permitted by the CCPA regulations).

Categories collected in the last 12 months: identifiers; customer records; protected characteristics (age, sex); commercial information (subscriptions); internet/device activity; sensitive personal information (account login, health information, photos). Sources: you, your device, and our processors. Purposes: as described in section 2. We disclose these categories to service providers only, for business purposes.

12. Consumer Health Data (Washington, Nevada, Connecticut and other states)

This section is our Consumer Health Data Privacy Policy under the Washington My Health My Data Act (RCW 19.373), Nevada SB 370 and similar laws.

• Health data we collect: weight, height, body-composition estimates, body and progress photos, food intake, dietary restrictions and allergies, injuries, workouts and fitness goals.
• Why: only to provide the features you request (targets, programs, analysis, progress tracking) and to keep the service safe.
• Sources: you, and estimates we derive from what you provide.
• Sharing: only with the processors in section 7, and with other users only when you post it. We never sell consumer health data.
• Consent: we ask for your separate, explicit consent before collecting health data and before processing body photos. You can withdraw it at any time in Settings.
• Your rights: confirm whether we hold your health data, access it, see the list of third parties and affiliates we share it with, withdraw consent, and have it deleted — using the methods in section 6. You may appeal a denied request by replying to our response; if your appeal is denied you can contact the Washington Attorney General.

We do not use geofencing around health-care facilities.

13. U.S. State Privacy Rights

Residents of Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Iowa, Delaware, New Jersey, New Hampshire, Minnesota, Maryland, Tennessee, Indiana, Kentucky, Nebraska and other states with comprehensive privacy laws have rights to access, correct, delete and port their data and to opt out of targeted advertising, sale and profiling with legal effects. We do not sell data, do not do targeted advertising, and do not profile in ways that produce legal or similarly significant effects. Processing of sensitive data (health data) happens only with your consent. To appeal a decision on your request, reply to our response with “Appeal”; we answer within the legal deadline.

14. Sensitive Information, Photos and Biometric Data

Health information and body photos are sensitive. We process them only with your explicit consent and only for features you turn on.

• Photos are private by default, stored in private storage, and shown only to you via links that expire within minutes — unless you post a photo to the community.
• Metadata removed: we strip location (GPS) and camera metadata from every image on upload.
• No face recognition, no biometric identifiers. We do not create face geometry, faceprints or any template that could identify you, and we do not use photos to identify people. Body analysis produces general estimates (for example a body-fat range and posture notes) only.
• Never used for training. Your photos and data are not used to train our or anyone else's AI models.
• You stay in control: delete any photo or analysis at any time; deletion removes the file from storage.

Body-composition estimates are approximations for general wellness and are not a medical assessment.

15. Do Not Sell or Share My Personal Information

We do not sell or share personal information as those terms are defined under California and other state laws, and we have not done so in the past 12 months. We honor Global Privacy Control signals on our website. No action is needed from you.

16. Automated Processing and Artificial Intelligence

Some features use AI models provided by Anthropic, at your request:

• Nutrition-label scanning — reads a label photo to fill in nutrition values for you to review.
• Body analysis — estimates a body-fat range and muscle-group emphasis from body photos to personalise your training program.
• Meal suggestions — proposes meals that fit your targets and preferences.
• Buddy from a selfie — if you choose “Make it from a selfie”, we look at the photo once to pick your cartoon buddy's look (hair style and colour, facial hair, eye colour, head shape and eyebrows; skin tone is never taken from the photo, you choose it yourself) from our fixed list of options. Location and other metadata are removed and the photo is downscaled first. The photo is never stored: it is not saved to our servers, database or logs, only the look options you choose to keep are saved with your buddy. We do not infer or keep your skin tone, age, ethnicity, religion, health, body weight or any other trait, other people in the photo are ignored, and photos of young children are not processed. This is not face recognition and creates no biometric identifier.

Calorie and macro targets are calculated by published, evidence-based formulas (with citations shown in the app), not by AI. AI outputs are estimates you can edit or ignore; none of them produce decisions with legal or similarly significant effects. Data sent for an AI request is processed transiently to return the result, is not used to train models, and is subject to our provider's commercial data-retention limits. You can withdraw AI-processing consent in Settings; the features that need it will then be unavailable.

17. EEA and UK Residents (GDPR)

GainBuddy Ltd. is the controller of your personal data. Our legal bases are:

• Contract (Art. 6(1)(b)) — to provide your account and the features you use.
• Explicit consent (Art. 9(2)(a)) — for health data and body photos, which are special-category data. You can withdraw consent at any time.
• Legitimate interests (Art. 6(1)(f)) — security, fraud prevention (including referral fraud), service improvement with aggregated data. You may object.
• Legal obligation (Art. 6(1)(c)) — tax, accounting and responding to lawful requests.

You have the rights of access, rectification, erasure, restriction, portability, objection, and not to be subject to solely automated decisions with legal or similarly significant effects (we make none). You may lodge a complaint with your supervisory authority. Our data protection contact: dpo@gainbuddy.fit. EU/UK representative: [to be appointed if required].

18. Israel (Privacy Protection Law, Amendment 13)

For users in Israel, this policy serves as the notice required under section 11 of the Protection of Privacy Law, 5741-1981, as amended by Amendment 13. Information about your health, body and eating habits is “information of special sensitivity”.

• You are not legally obliged to provide information; however, without it we cannot provide the related features (for example targets require height and weight).
• The purposes of use and the recipients of the information are described in sections 2, 3 and 7.
• You have the right to review your information (sections 6 and the in-app export) and to request its correction or deletion if it is inaccurate, incomplete, unclear or out of date.
• Our database is managed with the security measures required by the Protection of Privacy (Data Security) Regulations, 5777-2017. Where required, we register the database and have appointed a privacy protection officer, contactable at dpo@gainbuddy.fit.
• You may contact the Privacy Protection Authority if you believe your rights were infringed.

19. Contact Information

GainBuddy Ltd., [Registered address — to be completed]. Privacy requests: privacy@gainbuddy.fit. Data protection officer: dpo@gainbuddy.fit.