Privacy Policy

1. Introduction and Scope

This Privacy Policy explains how FitCommit AI Inc., a corporation incorporated under the Canada Business Corporations Act with its registered office in Ontario, Canada ("FitCommit," "we," "our," "us"), collects, uses, stores, shares, and protects your personal information when you use the FitCommit iOS app, the fitcommit.ai website, and related features (together, the "Services").

This policy applies to all users of the Services worldwide. We disclose region-specific rights and obligations under applicable laws including the European Union General Data Protection Regulation (GDPR), the United Kingdom GDPR, the Swiss Federal Act on Data Protection, the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), the California Consumer Privacy Act and the California Privacy Rights Act (CCPA/CPRA), the Washington My Health My Data Act, the Delaware Personal Data Privacy Act (DPDPA), and other US state privacy laws. Region-specific notices are in section 16, section 17, section 18, and section 19.

Your use of the Services is also governed by our Terms of Service. If you do not agree with this Privacy Policy, do not use the Services.

2. Definitions

• App means the FitCommit mobile application available on the Apple App Store.
• Account means the personal account you create to access the Services.
• Body Scan means the photo-based body composition estimate generated by our AI from images you upload.
• After Photo means the AI-generated visualization of a possible future body state at a target body fat percentage.
• Personal Information means information that identifies, relates to, or could reasonably be linked with you, including under CCPA/CPRA the categories listed in section 16.
• Health Data means data about your body, fitness, nutrition, and goals, including height, weight, body fat percentage, lean mass, calorie targets, and macro targets.
• Photo means any image you upload to the Services, including Body Scan source photos and progress photos.
• Meta Platform Data means creator and business information made available to FitCommit through Meta's authorized APIs.
• Service Providers means third parties we use to operate the Services (cloud hosting, payment processing, analytics, AI model providers).
• Advertising and Attribution Providers means third parties, including AppsFlyer and Meta, that help attribute installs, measure advertising performance, or personalize advertising where you grant permission.

3. Information We Collect

We collect the following categories of Personal Information:

• Account information. Name, email address, password (hashed), date of birth, sex, and account preferences.
• Health Data. Height, current weight, target weight, body fat percentage, lean mass, activity level, goals, calorie targets, and macro targets. See the Nutrition and Health Information section of our Terms of Service for the full disclaimer about how this data is interpreted.
• Photos. Body Scan source photos and any progress photos you upload. See section 8 for how photos are processed and stored.
• AI Output. The estimates and visualizations generated by our AI from your inputs (Body Scan results, After Photo previews, weight loss timelines).
• Subscription and payment information. We receive your subscription plan, billing status, and a transaction reference from the Apple App Store. FitCommit does not collect, receive, or store your card details. Subscriptions are processed by Apple and require a valid payment method on your Apple Account.
• Device and usage data. IP address, device model, operating system version, app version, device identifiers (including Apple's advertising identifier when you grant App Tracking Transparency permission), screens viewed, features used, advertising attribution and campaign data, crash logs, performance metrics, and similar telemetry.
• Cookies and similar tracking. See section 11.
• Communications. Email and in-app messages you send us, and our responses.
• Creator and business information. When the client-authorized integration is used, we receive creator profile information, professional account details, audience and content metrics, and related business information made available through Meta's authorized APIs. We use this information only to identify creator accounts and support FitCommit's creator partnership workflow.

We do not knowingly collect Personal Information from children under 13. See section 20.

4. Sources of Information

We collect Personal Information from these sources:

• Directly from you when you create an Account, complete onboarding, upload a Body Scan photo, set goals, or contact us.
• Automatically from your device when you use the Services (device and usage data, cookies).
• From the Apple App Store for purchase and subscription status.
• From integrated services if you choose to connect them (for example, Apple Health). You control which data syncs.
• From service providers for analytics, fraud prevention, and security.
• From attribution providers, including AppsFlyer, which returns install attribution and campaign information to the App.
• From Meta through authorized APIs when FitCommit uses its client-authorized creator partnership integration.

5. How We Use Your Information

We use Personal Information for the following purposes:

• Provide the Services. Generate your Body Scan estimate, calculate calorie and macro targets, render After Photo previews, and track progress.
• Personalize your experience. Tailor recommendations, dashboards, and reminders based on your goals and progress.
• Maintain your Account. Authenticate logins, sync data across sessions, and recover access.
• Process payments. Confirm subscription status with the Apple App Store.
• Improve the Services. Diagnose bugs, measure performance, and refine the user experience using aggregated and de-identified usage data.
• Measure and personalize advertising. Attribute installs, evaluate FitCommit advertising and creator campaigns, and, where you grant App Tracking Transparency permission, allow Meta to use device identifiers and app-interaction data to measure and personalize advertising shown to you on other companies' apps and websites. If you deny permission, the App does not access Apple's advertising identifier and this data is not used to personalize advertising across other companies' apps and websites.
• Apply creator referral offers. When AppsFlyer attributes your first launch of the App to an eligible creator campaign, we use the campaign name to determine whether you qualify for a promotional offer, such as an extended free trial. The eligible campaign name is stored on your device in the iOS Keychain and is used only to check and apply that offer.
• Improve our AI models. Subject to the limits in section 8, we use aggregated and de-identified data derived from your inputs to improve estimate accuracy.
• Communicate with you. Respond to support requests, send transactional notices (security, billing, policy changes), and, with your consent, send marketing.
• Comply with law. Meet legal, tax, and regulatory obligations and enforce our Terms of Service.
• Protect the Services. Detect, prevent, and respond to fraud, abuse, security incidents, and unauthorized access.
• Support creator partnerships. When the client-authorized integration is used, identify creator accounts and support FitCommit's creator partnership workflow using Meta Platform Data made available through authorized APIs.

6. Legal Bases for Processing (GDPR)

If you are in the European Union, EEA, Switzerland, or the United Kingdom, we rely on one or more of the following legal bases under GDPR Article 6 to process your Personal Information:

• Contract. Processing necessary to provide the Services you signed up for, including generating your Body Scan, calculating targets, and managing your Account.
• Consent. Where you have given us specific consent (for example, to use your photos for AI model training, to send marketing emails, or to integrate with Apple Health). Where Apple's App Tracking Transparency framework applies, we rely on your App Tracking Transparency choice before accessing Apple's advertising identifier or tracking you across other companies' apps and websites. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Legitimate interests. Where permitted without consent, for improving the Services, securing them against fraud and abuse, conducting analytics on aggregated and de-identified data, measuring installs and the performance of our own advertising and creator campaigns, including the install and app-open information AppsFlyer receives when you deny or have not yet answered the App Tracking Transparency prompt, and supporting FitCommit's creator partnership workflow, balanced against your rights.
• Legal obligation. To comply with applicable law, regulation, or court order.
• Vital interests. In the rare event that processing is needed to protect someone's life or physical safety.

For Health Data, we rely on your explicit consent (GDPR Article 9(2)(a)) granted at signup and reaffirmed each time you upload a Body Scan.

7. Automated Decision-Making

The Services use AI to generate estimates from your inputs (Body Scan, After Photo, calorie and macro targets, weight loss timelines). This is automated processing within the meaning of GDPR Article 22.

None of these AI outputs produce legal or similarly significant effects on you. They are informational and motivational estimates. They do not determine credit, employment, insurance, healthcare, housing, or any other legally significant outcome. See the Nutrition and Health Information section of our Terms of Service for the full disclaimer.

If you are in the EU, UK, or Switzerland, you have the right to request human review of an AI estimate that you believe is materially wrong. Contact privacy@fitcommit.ai.

8. Photos and AI Model Training

Your identifiable photos are not used to train our AI models without your separate, opt-in consent.

Body Scan and progress photos you upload are processed by our AI to generate your estimates and visualizations. Photos are stored encrypted in our cloud storage and are accessible only to you and to FitCommit personnel under strict access controls for support and abuse-investigation purposes.

We may use aggregated and de-identified data derived from photos (for example, body composition statistics with no identifying information) to improve the accuracy of our AI models. This data cannot reasonably be linked back to you.

You may delete any individual photo from within the App at any time. Deleted photos are removed from active storage immediately and from backup storage within 30 days. See section 12 for the full retention schedule.

We do not sell your photos. We do not license your photos to third parties for any purpose. We do not use your photos in marketing without your separate written consent.

9. How We Share Your Information

We share Personal Information only as described below. We do not sell Personal Information for money. See section 16 for how the CCPA/CPRA terms "sale" and "sharing" apply to our advertising and attribution disclosures.

• Service Providers. Cloud hosting (Google Cloud), payment processing (Apple), AI model providers, product analytics (PostHog), error reporting, and security. These providers act on our instructions under written contracts and may not use your data for their own purposes.
• Advertising and attribution providers. AppsFlyer receives device identifiers, app-interaction data, and campaign data to attribute installs and measure advertising performance. Where you grant App Tracking Transparency permission, Meta may receive device identifiers and app-interaction data to measure advertising performance and personalize advertising shown to you on services owned by other companies. If you deny permission, the App does not access or share Apple's advertising identifier. AppsFlyer still receives install and app-open information for aggregate campaign measurement. We do not share Health Data or photos with these providers.
• Attainment Labs Inc. When FitCommit uses its Meta integration, Attainment acts as a Tech Provider on FitCommit's behalf and at FitCommit's direction. FitCommit determines the purpose and approved access. Attainment may process Meta Platform Data only on FitCommit's documented instructions to provide the client-authorized integration. It may not sell the data or use it for its own advertising, marketing, or unrelated purposes.
• Apple, Inc. For App Store purchases, subscription management, and required platform telemetry.
• Legal compliance. When required to comply with law, valid legal process (for example, court order, subpoena), or to protect the rights, property, or safety of FitCommit, our users, or others.
• Business transfers. In connection with a merger, acquisition, financing, reorganization, sale of assets, or insolvency. We will notify you of any such change of ownership or control of your Personal Information.
• With your consent. Any other sharing requires your explicit consent.

10. Health Data Carve-Out

We do not sell Health Data. We do not use Health Data for advertising. We do not share Health Data with third parties for their own marketing or analytics.

Health Data and photos are processed only to deliver the Services to you and to maintain and improve the Services as described in this policy. This commitment applies in all jurisdictions, regardless of whether local law requires it. It also applies to any data we receive from Apple Health if you choose to connect it.

App-interaction events that record your use of health-related features, such as whether you started or completed a Body Scan, are processed by PostHog for product analytics. Integrated advertising and attribution SDKs may also process limited app-interaction data as described in section 11. The underlying Health Data, including your measurements, body composition results, calorie and macro targets, and your photos, is never shared with advertising or attribution providers.

11. Cookies and Tracking

The fitcommit.ai website uses cookies and similar tracking technologies for the following purposes:

• Strictly necessary. Authentication, security, load balancing.
• Analytics. PostHog provides aggregated traffic measurement, feature usage, page performance, CTA measurement, and privacy-masked session replay for troubleshooting and website improvement. We configure analytics to avoid collecting health data, photos, payment details, and form-entered personal information from the website.
• Preferences. Remembering your settings (for example, dark mode).

You can manage cookies through your browser settings. Blocking strictly necessary cookies may break parts of the website.

In the FitCommit iOS app:

FitCommit uses PostHog for product analytics and AppsFlyer and Meta SDKs for advertising attribution and measurement. PostHog product analytics operates regardless of your App Tracking Transparency choice. The App requests permission through Apple's App Tracking Transparency framework before accessing Apple's advertising identifier or tracking your activity across apps and websites owned by other companies. If you grant permission, Meta may use device identifiers and app-interaction data to measure advertising performance and personalize advertising shown to you on services owned by other companies. If you deny permission, the App does not access Apple's advertising identifier and does not track your activity across other companies' apps and websites. AppsFlyer still receives install and app-open information for aggregate campaign measurement. FitCommit's core features remain available either way. You can change this choice in iOS Settings under Privacy & Security, then Tracking.

12. Data Retention

We retain Personal Information only as long as needed for the purposes described in this policy. Specific retention periods:

• Account information (name, email, preferences): retained while your Account is active. Deleted within 30 days of Account deletion.
• Health Data (height, weight, body fat, targets): retained while your Account is active. Deleted within 30 days of Account deletion.
• Photos (Body Scan source, progress): retained while present in your Account. Individual photo deletions removed from active storage immediately and from backups within 30 days. Account deletion removes all photos within 30 days.
• Subscription records: retained for the duration of the subscription plus 7 years to meet tax, accounting, and audit obligations.
• Device and usage telemetry: retained in identifiable form for 90 days, then aggregated or deleted.
• Creator campaign attribution: an eligible campaign name may be stored on your device in the iOS Keychain and is used only to check and apply a promotional offer.
• Crash logs: retained for 90 days.
• Support and communications: retained for 3 years from the last interaction, then deleted.
• Meta Platform Data: when obtained through the client-authorized integration, retained only while needed for the creator partnership purpose. We delete it as soon as reasonably possible when it is no longer needed, when the integration stops, or when Meta or the Meta user whose data it concerns requests deletion, except where law requires documented retention.
• Aggregated and de-identified data: may be retained indefinitely as it cannot reasonably be linked to you.
• Backups: rolling 30-day window. Deleted Personal Information persists in backups for up to 30 days, then is permanently removed.
• Legal hold: where law requires longer retention (for example, fraud investigation, litigation hold), we retain only the specific records subject to the hold for the period required.

13. Data Security

We use industry-standard technical and organizational measures to protect Personal Information, including encryption in transit (TLS 1.2 or higher) and at rest, access controls based on least privilege, audit logging, and periodic security assessments. Photos and Health Data receive additional access restrictions.

No method of transmission or storage is fully secure. If we become aware of a security incident affecting your Personal Information, we will notify you and the relevant supervisory authorities as required by applicable law.

14. International Data Transfers

FitCommit operates from Canada and the United States. Your Personal Information may be transferred to, stored in, and processed in countries other than your country of residence, including the United States, where data protection laws may differ from those in your country.

For transfers from the EEA, UK, or Switzerland to countries that have not received an adequacy decision, we rely on the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum, where applicable) and supplementary measures. For transfers from Canada, we comply with PIPEDA cross-border transfer requirements. You may request a copy of these safeguards by contacting privacy@fitcommit.ai.

15. Your Privacy Rights

Depending on where you live, you may have the following rights with respect to your Personal Information:

• Access. Request a copy of the Personal Information we hold about you.
• Correction. Ask us to correct inaccurate or incomplete information.
• Deletion. Ask us to delete your Personal Information. See section 22.
• Portability. Receive your Personal Information in a structured, commonly used, machine-readable format.
• Opt-out of marketing. Unsubscribe from marketing emails at any time.
• Object or restrict processing. Object to certain processing or ask us to restrict it.
• Withdraw consent. Where we rely on consent, you may withdraw it at any time.
• Opt out of targeted advertising or sharing. Where applicable, deny or revoke App Tracking Transparency permission in iOS Settings or contact privacy@fitcommit.ai.
• Lodge a complaint. File a complaint with your local data protection authority.

To exercise any right, contact privacy@fitcommit.ai. We will respond within 30 days (45 days for EEA/UK requests, extendable by 60 days for complex requests) and will verify your identity before disclosing or deleting any Personal Information. We do not discriminate against you for exercising your rights.

16. Notice for California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act and California Privacy Rights Act (together, the "CCPA/CPRA") give you the rights described below. We do not sell your Personal Information for money. Where you grant App Tracking Transparency permission, our disclosure of device identifiers and app-interaction data to advertising and attribution providers may constitute "sharing" for cross-context behavioral advertising as defined by the CCPA/CPRA. You may opt out at any time by denying or revoking App Tracking Transparency permission in iOS Settings, or by contacting privacy@fitcommit.ai. We do not use or disclose Health Data or photos for cross-context behavioral advertising.

Categories of Personal Information collected in the last 12 months:

• Identifiers. Name, email address, IP address, device identifiers. Sources: you, your device, service providers. Used for: providing the Services, security, communications, product analytics, advertising attribution and measurement. Shared with: Service Providers and advertising and attribution providers. Disclosures that constitute "sharing" for cross-context behavioral advertising occur only where you authorize tracking.
• Customer records (Cal. Civ. Code § 1798.80(e)). Account information, contact information. Sources: you. Used for: providing the Services. Shared with: Service Providers.
• Commercial information. Subscription plan, billing status. Sources: Apple App Store. Used for: managing your subscription. Shared with: Service Providers, Apple.
• Internet or network activity. App and website usage, performance, crash logs. Sources: your device. Used for: improving the Services, security, analytics, advertising attribution and measurement. Shared with: Service Providers and advertising and attribution providers. Disclosures that constitute "sharing" for cross-context behavioral advertising occur only where you authorize tracking.
• Sensitive personal information. Health Data, photos, account credentials. Sources: you. Used for: providing the Services. Shared with: Service Providers under strict contracts. We use sensitive personal information only for the purposes permitted under CPRA Section 1798.121.
• Inferences. AI-generated body composition estimates, calorie targets, macro targets. Sources: your inputs. Used for: providing the Services. Shared with: Service Providers.

Categories we expect to collect when the client-authorized Meta integration is used:

• Identifiers. Creator account names or handles.
• Internet or network activity. Creator content information and audience or content metrics.
• Professional or employment-related information. Professional account details and related business information.

Source: Meta. Purpose: identify creator accounts and support FitCommit's creator partnership workflow. Recipient: Attainment Labs Inc., acting as a Tech Provider on FitCommit's behalf and at FitCommit's direction.

Your CCPA/CPRA rights: right to know, right to delete, right to correct, right to portability, right to opt out of sale or sharing, right to limit use of sensitive personal information, and right to non-discrimination. We do not sell Personal Information for money. Where you grant App Tracking Transparency permission, our disclosures to advertising and attribution providers may constitute "sharing" as described above. You can deny or revoke App Tracking Transparency permission for app tracking and may also contact privacy@fitcommit.ai to exercise your rights. You may designate an authorized agent.

We do not knowingly sell or share Personal Information of consumers under 16 without affirmative authorization.

17. Notice for EEA, UK, and Switzerland (GDPR)

If you are located in the European Economic Area, United Kingdom, or Switzerland, the GDPR (and UK GDPR and Swiss FADP, as applicable) apply to our processing of your Personal Information.

Controller. FitCommit AI Inc. is the data controller for the Personal Information described in this policy. It is federally incorporated in Canada and has its registered office in Ontario.

Legal bases. See section 6.

Your rights. Access, rectification, erasure, restriction of processing, data portability, objection to processing (including profiling), withdrawal of consent, and the right to lodge a complaint with your supervisory authority. To exercise any right, contact privacy@fitcommit.ai or our Data Protection Officer at dpo@fitcommit.ai.

EU representative. We are evaluating designation of an EU representative under GDPR Article 27. Until appointed, please send GDPR-related inquiries to dpo@fitcommit.ai for our prompt response.

International transfers. See section 14.

18. Notice for Canada (PIPEDA)

For Canadian residents, the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws (including Quebec's Law 25, British Columbia's PIPA, and Alberta's PIPA) apply to our handling of your Personal Information.

You have the right to access and correct your Personal Information, withdraw consent, and file a complaint with the Office of the Privacy Commissioner of Canada or your provincial commissioner. Contact privacy@fitcommit.ai to exercise these rights.

19. Notice for Other US States

If you are a resident of Washington, Texas, Virginia, Colorado, Connecticut, Utah, Oregon, Tennessee, Indiana, Iowa, Montana, or Delaware, the privacy laws of your state may apply.

Washington My Health My Data Act. Health Data and photos qualify as Consumer Health Data under this law. We collect and process Consumer Health Data only with your consent (granted at signup and at each Body Scan upload), only to provide, maintain, and improve the Services as described in section 10, and we do not sell Consumer Health Data. You have the right to access, delete, and withdraw consent. Contact privacy@fitcommit.ai.

Across all listed states, you generally have the rights to access, delete, correct, port, and opt out of the sale of Personal Information and targeted advertising. We do not sell Personal Information for money, and we do not use Health Data or photos for targeted advertising. Where you grant App Tracking Transparency permission, app device identifiers and usage data may be used for targeted advertising as described in section 11. You may opt out by denying or revoking that permission in iOS Settings or by contacting privacy@fitcommit.ai.

20. Children's Privacy

The Services are intended for users 13 and older. We do not knowingly collect Personal Information from children under 13 in compliance with the United States Children's Online Privacy Protection Act (COPPA). If you believe a child under 13 has provided us with Personal Information, contact us at privacy@fitcommit.ai and we will delete it. Users between 13 and 17 must have permission from a parent or legal guardian.

21. Marketing Communications

We send marketing communications only with your consent. You can opt out at any time by following the unsubscribe link in any marketing email or by contacting privacy@fitcommit.ai. Opting out of marketing does not affect transactional messages (security notices, billing, policy changes).

22. Account Deletion

You can delete your FitCommit Account at any time directly within the App. Go to Settings, select Account, and tap Delete Account.

When you delete your Account, we permanently delete:

• Account information (name, email, preferences).
• All photos (Body Scan source, progress, After Photo previews).
• Health Data (weight, body fat, calorie and macro targets, history).
• AI Output linked to your Account.

Deletion is permanent and cannot be undone. Active-storage deletion happens immediately. Backup-storage deletion completes within 30 days. We retain subscription and tax records as described in section 12.

23. Apple-Specific Notes

The FitCommit App is distributed through the Apple App Store. Apple's privacy practices apply to your Apple Account, App downloads, and in-app purchases. FitCommit does not collect, receive, or store your card details. Subscriptions are processed by Apple and require a valid payment method on your Apple Account.

If you connect Apple Health, only the data categories you authorize are shared with the App. We use Apple Health data only to provide the Services and we do not store Apple Health raw data on our servers beyond what is needed for active sessions, unless you explicitly opt in to a long-term sync.

The App requests permission through Apple's App Tracking Transparency framework. If you grant permission, device identifiers and app-interaction data may be used by AppsFlyer and Meta to measure advertising performance, and by Meta to personalize advertising, across apps and websites owned by other companies. If you deny permission, the App does not access Apple's advertising identifier and does not track you across other companies' apps and websites. AppsFlyer still receives install and app-open information for aggregate campaign measurement. See section 11 for details.

24. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date at the top, list the change in section 26, and, for material changes, notify you in the App or by email at least 30 days before the change takes effect. Continued use of the Services after a change becomes effective means you accept the updated policy.

25. Contact Us

For questions about this Privacy Policy or to exercise any privacy right:

26. Revision History

• August 13, 2026: Corrected the App Tracking Transparency disclosure to match the current iOS app and App Store privacy label. Added disclosures for PostHog product analytics, AppsFlyer and Meta advertising attribution, advertising personalization after ATT permission, health-feature interaction events, and creator referral offer eligibility. Clarified the data processed after ATT denial and preserved the prohibition on sharing underlying Health Data or photos with advertising and attribution providers.
• August 9, 2026: Added disclosures for Meta creator and business information, clarified Attainment Labs Inc.'s limited role as a Tech Provider acting on FitCommit's behalf and at FitCommit's direction, corrected FitCommit's Canadian corporate identity and controller jurisdiction, and added its verified registered-office address.
• July 28, 2026: Clarified that Apple processes subscriptions, Apple Accounts require a valid payment method, FitCommit does not collect, receive, or store card details, and customer-support inquiries go to support@fitcommit.ai.
• April 26, 2026: Major revision. Added Definitions, Sources of Information, Legal Bases for Processing (GDPR Article 6 with Article 9(2)(a) for Health Data), Automated Decision-Making (Article 22) with right to human review, Photos and AI Model Training (no training on identifiable photos without opt-in), Health Data Carve-Out (no sale, no advertising), specific Data Retention periods per category, dedicated Notices for California (CCPA/CPRA with categories table), EEA/UK/Switzerland (GDPR + DPO), Canada (PIPEDA + provincial laws), Other US States (Washington MHMD, Texas, Virginia, Colorado, Connecticut, Utah, and others), Apple-Specific Notes (App Tracking Transparency, Apple Health). Added Quick Links table of contents, BreadcrumbList and WebPage JSON-LD schema, dedicated dpo@/security@ contacts.
• April 10, 2026: Effective date update.