Privacy Policy

Effective date: January 11, 2025

Last updated: October 26, 2026

Introduction

Fitless ("Fitless", "we", "us", or "our") is an AI-powered personal fitness training platform that delivers personalized workouts through body analysis and computer vision. This Privacy Policy explains how OPALLOO INOVACOES LTDA (CNPJ: 53.284.020/0001-06) collects, uses, shares, and protects your personal information when you use our website at fitless.ai, the Fitless mobile application, and the Fitless plugin in ChatGPT and Claude (collectively, the "Services").

This Policy explains how we handle your personal data. It is not a request for consent: when processing depends on your consent, we ask for it on a separate screen or checkbox, and you can decline.

Table of Contents

  1. Information We Collect
  2. How We Use Your Information
  3. Body Scan Images and AI Analysis
  4. How We Share Your Information
  5. Third-Party Services
  6. Data Retention
  7. Data Security
  8. Your Rights and Choices
  9. International Data Transfers
  10. Children's Privacy
  11. Changes to This Policy
  12. Contact Us

1. Information We Collect

Sensitive Health Data Notice

IMPORTANT: Our Services collect and process sensitive personal data related to your health, including body measurements, health conditions, injuries, medications, and body scan images. Under data protection laws such as GDPR and LGPD, this type of information is classified as "special category data" or "sensitive personal data" and requires your explicit consent for processing.

We rely on your specific, highlighted consent to process your sensitive health data, always separate from your acceptance of the Terms of Use and this Policy. The health data in the quiz (injuries, weight, height and age) has its own checkbox in the quiz, which you check before finishing it. The AI body analysis has a dedicated opt-in, shown before the photos. Apple Health and Health Connect have a notice on the connection screen, before the system permission. Menstrual cycle tracking is only turned on if you choose to. In the Fitless plugin in ChatGPT and Claude, pain regions have a card of their own, shown before anything is stored. We record each consent together with its purpose, the policy version, and a timestamp. The body analysis, the Apple Health or Health Connect connection and cycle tracking are optional: you can generate a workout plan without any of them. The quiz health data is needed to build a plan that is safe for you, so the quiz can only be finished with that consent.

You have the right to withdraw this consent at any time by deleting your account or contacting us at privacy@fitless.ai. However, withdrawing consent may affect our ability to provide the Services to you.

Information You Provide

  • Account Information: Email address, name, username, and password when you create an account.
  • Health Profile (Sensitive Data): Height, weight, body fat percentage, fitness goals, fitness level, workout preferences, available equipment, health conditions, injuries, and medications. This is considered sensitive health data and is processed with your explicit consent.
  • Body Scan Images (Sensitive Data): Front and side photographs you upload for AI-powered body composition analysis. These images are processed with your explicit consent and are deleted immediately after analysis.
  • Workout Data: Exercise history, completed workouts, personal records, sets, reps, and performance metrics.
  • Supplements and Hydration: The creatine, whey, and water intake entries you log in the app, with the date of each entry and the amount where applicable. We use this to maintain your streaks and reminders.
  • Check-in Photos: If you attach a photo when logging a workout, it is kept in private storage, reachable only through temporary links minted for your own app. These photos are not public.
  • Social Features: Friends list, friend requests, and any progress you choose to share.
  • Payment Information: Billing details processed securely through our payment providers (Stripe for purchases on our website; Apple for in-app purchases made in the iOS app; Google for in-app purchases made in the Android app). We never receive or store your full credit card number.
  • Communications: Messages you send to our support team, feedback, and survey responses. If you attach images to feedback, they are kept in private storage and reach our support team through a temporary link, valid for 7 days, solely so we can investigate what you reported. Because screenshots can contain personal data, avoid attaching images with information you would rather not share.

Information Collected Automatically

  • Device Information: Device type, operating system, browser type, and unique device identifiers.
  • Usage Data: Pages visited, features used, workout completion rates, app interactions, and session duration.
  • Log Data: IP address, access times, referring URLs, and error logs.
  • Location Data: General location based on IP address (we do not collect precise GPS location).
  • Cookies and Tracking: We use cookies, pixels, and similar technologies for analytics and advertising purposes, according to the choice you make in the cookie notice described below.
  • Motion Sensors: In the mobile apps, we read the device accelerometer so your card, stickers, and membership card tilt and catch the light as you move your phone. This is used only for the animation, in real time, and never leaves your device.

Cookies and Consent

On our website, cookies and similar technologies fall into three categories:

  • Essential: required for the site to function, such as session, security, and language preference. These cannot be switched off.
  • Analytics: measure how the site is used so we can improve it.
  • Marketing: measure the effectiveness of our campaigns and attribute conversions.

On your first visit, a notice offers two options: "Accept all", which enables all three categories, and "Essential only", which keeps just the first. Until you accept all, analytics and advertising scripts are not loaded and the corresponding events are not sent.

Your choice is stored in your browser. To change it, clear the site's cookies in your browser settings and the notice will appear again on your next visit.

Our iOS and Android apps do not show this notice because they do not use browser cookies or load advertising scripts. Our web app (app.fitless.ai) does not load advertising scripts either; there and in the apps, we use only the product analytics described below, which in the web app stores an identifier in your browser's local storage.

Our website does not currently respond to browser "Do Not Track" signals. If you accept marketing cookies, Meta may collect information about your activity on our website and on other websites over time.

Product Analytics (Website and Mobile Apps)

We use PostHog for product analytics on our website and on our iOS and Android apps. Analytics events include:

  • Usage events: Actions taken in the product, such as a workout being generated or completed, and screens viewed.
  • Device and app metadata: Device model, operating system version, app version, and language/locale.

Analytics events are associated with your account identifier and its email address so that we can understand how the product is used and improve it. When you delete your account, we request that PostHog delete your analytics identity and the events associated with it.

By design, analytics events never include your health data, your photographs or body scan images, or the content of your workouts. Analytics data is processed by PostHog on cloud infrastructure hosted in the United States (see "International Data Transfers").

Subscription and Purchase Data

When you subscribe to Fitless Pro through the App Store or Google Play, we receive and store limited subscription data from Apple or Google in order to manage your access to paid features:

  • Apple or Google Play transaction identifiers.
  • The subscription product purchased, its status, and its expiry date.
  • Server notifications (webhook events) from Apple and Google Play about subscription events, such as renewals, cancellations, and refunds.

We never receive your payment card details for any purchase; payment is handled entirely by Apple (for App Store purchases), Google (for Google Play purchases), or Stripe (for web purchases).

Apple Health and Health Connect Data

If you choose to connect Fitless to Apple Health (iOS) or Health Connect (Android), we may, with the permission you grant in the operating system itself:

  • Read: height, weight, body fat percentage, exercise sessions, and heart rate, to pre-fill your health profile, display metrics during workouts (including on your watch), and personalize your plans.
  • Write: your completed workouts and exercise minutes, so your history is recorded in your device's health app.

This data is treated as sensitive health data and used exclusively to provide the features described above. We never use it for advertising, never sell it, and never share it with third parties, except with the infrastructure providers required to operate the Services (such as Contabo, where your health profile is stored). You can revoke these permissions at any time in your device's Apple Health or Health Connect settings, and deleting your account removes the derived data we store.

Connected Watches and Devices

If you install the Fitless app on a Garmin watch, we store what is needed to authorize that watch to reach your account: a device identifier, the model name, the permissions granted, the authorization's expiry, the date it was last used, and a hash of the access token. We store the hash, never the token itself.

The watch uses that authorization to fetch your workout of the day and the exercise animations. You can revoke access by removing the app from the watch, and deleting your account removes the authorization along with it.

Fitless in ChatGPT and Claude

You can ask for a Fitless workout plan inside a conversation in ChatGPT, by OpenAI, or in Claude, by Anthropic, using the Fitless plugin. The plugin is free, works without signing in, and sells nothing inside those platforms.

What the plugin receives. When you ask for a plan, the assistant (ChatGPT or Claude) sends the plugin only the answers needed to build it:

  • Training: goal, fitness level, training days per week, and minutes per session.
  • Location: gym or home and, for home workouts, the equipment you have.
  • Profile: sex and age.
  • Pain adaptation (optional): only a yes or no, indicating whether the plan should be adapted for pain.

The plugin's instructions ask the assistant not to ask about pain or injuries and never to send us the names of body regions, diagnoses, or medications, and the plugin has no field to receive them. Pain regions (Sensitive Data, optional) only reach us through the Fitless card, when you pick them from a closed list (back, knees, shoulders, neck, elbows, feet, and hips), as explained below.

We do not receive your name, your email, or the rest of the conversation. ChatGPT also sends a hint of your language and approximate location: we use the language to write the plan in it, and we do not store the location. When the exercise animations in the card load from Fitless servers, we receive your IP address and browser type, as with any visit to our website (see "Log Data").

What we use it for. To build your workout plan and choose the exercises. The pain regions are used only to remove from the plan the exercises that strain that region: we do not diagnose, we do not recommend medication, and we do not use this data for advertising. We do not sell this data. If the plan does not need to be adapted for pain, we store the request and generate the plan right away, without the consent card.

Consent for pain regions. If you say in the conversation that you are in pain, the assistant only tells the plugin that the plan should be adapted; it does not send us which region it is. You pick the region in a Fitless card, inside the conversation. The card says what we use the region for, where it is processed, and how long it is kept. Only after you tap "Agree and generate" do we receive the region, store the request, and generate the plan, and we record the date, the time, the version of the text you accepted, and the platform. If you tap "Not now", we do not receive the region and we store nothing. You can ask for a plan without reporting any region. To withdraw your consent, send the plan link to privacy@fitless.ai: we delete the request and the plan.

Legal bases. For the pain regions, which are health data, the basis is your specific, highlighted consent, given in the plugin card before we receive the region (LGPD Art. 11, I; GDPR Art. 9(2)(a)). For the other answers, the basis is performing the service you asked for (LGPD Art. 7, V; GDPR Art. 6(1)(b)). When we return the plan to the conversation, at your request, delivering it to OpenAI or Anthropic, in the United States, is necessary to provide the service you asked for (LGPD Art. 7, V, and Art. 33, IX). For the identifier described below and for usage statistics, the basis is our legitimate interest in preventing abuse and keeping the plugin free (LGPD Art. 7, IX; GDPR Art. 6(1)(f)). You can object to the use of the identifier and the statistics by writing to privacy@fitless.ai with the plan link.

Platform identifier. With each request, ChatGPT sends identifiers created by OpenAI for the person and for the conversation, which do not reveal your name or your email. In Claude, we do not receive this identifier, and there the plan limit applies to all requests together, not per person. We never store those identifiers: we store only a hash of each one, computed with a secret key of ours. The hash is pseudonymized data and is therefore still personal data. We use the hash to limit how many plans the same person can generate per day, to stop anyone else from looking up your plan through the plugin, and to count plugin usage. The usage events we record in PostHog (such as plan created, ready, or saved) carry the platform and technical data about the plan (plan identifier, days per week, language, generation time, number of attempts, error code, exercise shown, plan status, and whether it replaced an earlier plan), and never include the pain regions or any other health data. When the platform sends the identifier, the event is tied to the first 16 characters of the hash; when it does not, the event is tied to the plan identifier, or to no identifier when only an exercise was shown. The plan saved event is tied to your Fitless account. These events are not deleted along with the plan: they stay in PostHog for the retention period configured in PostHog. The hash does not give us access to your name, your email, or your account on the platform.

Retention. The request and the generated plan are kept for up to 30 days. If the plan is not saved to a Fitless account within that period, it is deleted automatically, along with the answers, the pain regions, and the hash. Failed requests are deleted within 7 days.

Saving the plan to your account. When the plan is ready, the card button opens a link, on www.fitless.ai, to save it to a Fitless account. Since the plugin does not ask you to sign in, the link is what proves the request is yours. So treat the link as personal: anyone who has it can save the plan to an account. The page shows only the plan's exercises, never the pain regions, age, or sex. To save, you sign in or create an account and accept the Terms of Use and this Policy. If the plan was adapted for pain, it is saved already adapted, and no pain region goes to your account: the regions are used only to adapt that plan. Once you save, the plan moves to your account and follows the rules of this Policy, and the plugin copy (the answers, including the pain regions, the generated plan, the summary, and the hashes) is deleted. All that remains is the record of origin, with the platform, the dates, and the status of the request, and the record of the consents you gave.

Who is involved. The plugin runs inside ChatGPT and Claude. OpenAI and Anthropic do not process data on behalf of Fitless: each of them handles the conversation as an independent controller, under its own privacy policy (see "Third-Party Services"). At your request, we return the plan to the conversation, with a summary so the conversation can continue about the workout. What we return does not include the pain regions, age, or sex. From then on, that content follows the platform's policy, in the United States. Plan generation follows the same path as the app and uses the providers already listed in this Policy: the answers, including the pain regions, go to Anthropic's (Claude) or OpenAI's (GPT) AI models through OpenRouter's zero-data-retention routing, and the request and the plan are kept on our servers at Contabo, all in the United States. Free text the AI writes while building the plan, which could mention the region, is removed from the plan we store and replaced by the names and instructions of Fitless's own catalog.

Adults only (18+). The plugin is intended for adults only. If the age provided is under 18, the plugin refuses the request, does not generate the plan, and stores nothing.

Your rights and deletion. You can exercise the rights described in "Your Rights and Choices". If you already saved the plan, it is part of your account and can be deleted like the rest of its data, including by deleting your account in the app's Settings. To delete a plan you did not save before the 30 days are up, send the plan link to privacy@fitless.ai, and we will delete the request and the plan.

Menstrual Cycle Tracking (Sensitive Data)

Fitless offers optional menstrual cycle tracking, used to adjust your training load to the phases of your cycle. The feature is off by default and collects no data until you turn it on, and we record the date and time of your consent at the moment you enable it.

While the feature is on, we store:

  • Cycle settings: average cycle and period length, the start date of your last period, and the load reduction percentage you chose to apply.
  • Period records: the period start dates you enter.
  • Check-ins: whether you are menstruating on a given day, the symptoms you select, and whether the workout was eased, which may be linked to the corresponding workout session.

This is sensitive reproductive health data. We process it exclusively with your explicit consent and use it only to adapt your workouts and to show you your own history inside the app.

We never use it for advertising, never sell it, and never share it with third parties. It does not appear in the social feed, in the ranking, or on any other surface visible to other people, and it is never included in analytics events. You can turn tracking off and delete all cycle data at any time in the app settings, and deleting your account removes it as well.

Achados and Product Links

The Achados section collects product recommendations and collections. When you tap a product link, we record which product was tapped, which part of the app the tap came from, and the date and time, associated with your account, so we can understand which recommendations are useful and organize the section.

Some of these links are affiliate links: if you make a purchase at the destination store, we may earn a commission at no additional cost to you. From the moment you leave Fitless and arrive at the store, the handling of your data is governed by that store's privacy policy and by the relevant affiliate network's policy. We do not receive your order details or your payment details from the store.

Reviews and Product Photos

If you review a product in the Achados section, we store your overall rating, the review text, the per-criterion ratings, and, if you attach one, the product photo.

Review photos are public. They live at an openly accessible address so they appear alongside your review for anyone viewing that product. Do not attach photos you would not want to make public, and avoid images showing you, other people, documents, or addresses.

Your reviews and any collections you mark as public are visible to other users alongside your username and profile picture. Private collections remain visible only to you. Products you suggest go through moderation before they appear to others.

Deleting your account removes your review photos from our storage.

2. How We Use Your Information

We use your information to:

  • Provide and personalize our Services: Generate custom workout plans based on your body analysis, fitness level, goals, and available equipment.
  • Process body scans: Analyze your uploaded images using AI to assess body composition and create tailored fitness recommendations.
  • Track your progress: Record workout history, streaks, and personal records to help you monitor your fitness journey.
  • Process payments and manage subscriptions: Handle subscription billing, refunds, and payment verification, and determine which features your account can access based on your subscription status (for example, Fitless Pro).
  • Enable social features: Allow you to connect with friends and share progress.
  • Communicate with you: Send transactional emails, workout reminders, and respond to support inquiries.
  • Improve our Services: Analyze usage patterns to enhance features, fix bugs, and develop new functionality.
  • Marketing (with consent): Send promotional content about our Services. You can opt-out at any time by clicking "Unsubscribe" in any marketing email or contacting us at support@fitless.ai.
  • Legal compliance: Comply with applicable laws, regulations, and legal requests.

Legal Bases for Processing

We only process your personal data when we have a valid legal basis. The basis depends on the data and the purpose:

| Purpose | Legal basis (LGPD / GDPR) | |---------|---------------------------| | Providing the Services (account, workouts, progress tracking) | Performance of our contract with you (LGPD Art. 7, V; GDPR Art. 6(1)(b)) | | Processing health data and body scan images | Your specific, highlighted consent for sensitive data (LGPD Art. 11, I; GDPR Art. 9(2)(a)) | | Billing, subscription management, tax, and fraud prevention | Performance of our contract, legal obligation, and our legitimate interests (LGPD Art. 7, V, II & IX; GDPR Art. 6(1)(b), (c) & (f)) | | Analytics, security, and improving the Services | Our legitimate interests, balanced against your rights (LGPD Art. 7, IX; GDPR Art. 6(1)(f)) | | Marketing communications | Your consent, withdrawable at any time (LGPD Art. 7, I; GDPR Art. 6(1)(a)) |

Where we rely on consent, you may withdraw it at any time without affecting processing already carried out. Where we rely on legitimate interests, you may object to that processing (see "Your Rights and Choices").

Automated Decision-Making and Profiling

We use artificial intelligence to analyze your body composition and generate personalized workout and nutrition recommendations. This involves automated processing of your data, including sensitive health data, to tailor the Services to you.

These recommendations are general fitness guidance, do not produce legal or similarly significant effects on you, and never replace professional medical advice. You have the right to request human review of, contest, or request an explanation about any automated decision that affects you (LGPD Art. 20; GDPR Art. 22). To exercise this right, contact privacy@fitless.ai.

3. Body Scan Images and AI Analysis

Your privacy regarding body scan images is extremely important to us. Here is exactly how we handle them:

Image Processing

  1. Upload: You upload front and side photographs through our secure, encrypted connection.
  2. Storage: Images are stored temporarily in a private storage bucket accessible only to you and our analysis system.
  3. Analysis: Images are sent to our AI providers (Claude models by Anthropic, or GPT models by OpenAI) through OpenRouter's zero-data-retention routing, which only uses model endpoints that do not store your data or use it to train their models. The provider processes the images solely to perform the analysis and does not retain them.
  4. Immediate Deletion: Images are deleted immediately after analysis is complete and are never written to our database — they exist only transiently during processing.
  5. Backup Cleanup: As an additional safeguard, an automated process runs every hour and permanently deletes any body scan image older than 2 hours, ensuring no image remains even if the primary deletion fails.

What We Keep

  • We store only the numerical results of your body analysis (e.g., estimated body fat percentage, muscle mass distribution, and fitness recommendations).
  • We do not retain your actual photographs after analysis.
  • Analysis results are associated with your account and used to personalize your workout plans.

The Copy on Your Device

For the progress comparison feature, the app keeps a copy of your scan photos on your own device, inside the app's private area:

  • Those copies are never sent to us and do not appear in your phone's photo gallery.
  • They are deleted when you sign out, when you delete your account, or when you delete the scan from the app. The app keeps only the most recent scans and automatically discards older ones.
  • On iOS, app files are included in your own Apple iCloud backup, under your control. On Android, the app's automatic backup is disabled.

Progress Comparison

When you request a comparison between two scans, both photos leave your device and go directly to our zero-data-retention AI provider within that same request. They are never written to a storage bucket, a database, or a log. Only the text and numbers of the analysis persist, associated with your account.

Your Control

  • You can request deletion of your analysis results at any time by contacting support@fitless.ai.
  • Deleting your account permanently removes all associated body analysis data.
  • The copy stored on your device leaves it when you delete the scan from the app or sign out.

Third-Party Photos in the "Cheer Squad" Widget

The Cheer Squad feature lets a subscriber invite another person to appear, as stylized stickers, on the subscriber's own phone widget. In this flow:

  1. Consent from the photo subject: the photo is uploaded by the photographed person themselves, who must be 18 or older, through an individual, time-limited link. They expressly authorize the AI transformation before uploading, and we record the date and version of the consent text they accepted.
  2. Processing: the photo goes through an automated content check and is transformed into stylized stickers by our AI provider (Google Gemini). Under the paid plan we use, the provider does not use the photo to train its models. It may retain it for a limited period solely to detect abuse and meet legal obligations, and for no other purpose.
  3. Deletion of the original photo: the uploaded photograph is deleted from our servers as soon as the stickers are ready. We retain only the stylized stickers.
  4. Where the stickers appear: only on the widget of the subscriber who sent the invite. They are not public and are not shown to other users.
  5. Revocation at any time: the photographed person receives a permanent revocation link. Using it deletes all stickers from our servers and from the widget, and the subscriber is notified. Deletion can also be requested at support@fitless.ai.

4. How We Share Your Information

We do not sell your personal information. We share your information only in the following circumstances:

Service Providers

We work with trusted third-party companies that help us operate our Services:

| Provider | Purpose | Data Shared | |----------|---------|-------------| | Stripe | Payment processing (web purchases) | Billing information, transaction details | | Apple | Payment processing for in-app purchases (App Store) | Purchase and subscription transaction data. Apple processes the payment; we never receive your card details | | Google Play | Payment processing for in-app purchases (Android) | Purchase and subscription transaction data. Google processes the payment; we never receive your card details | | Contabo | Hosting of our servers, database, authentication, and file storage, in the United States | Account data, health profiles, workout data, uploaded photos and files, access logs | | Cloudflare (R2) | Storage of backups, in Europe. Backups are encrypted before upload, and Cloudflare has no access to their content | Encrypted copy of the data stored on our servers | | Anthropic (Claude) and OpenAI (GPT), via OpenRouter | AI-powered body analysis, workout generation and check-in photo verification | Body scan images (sent via zero-data-retention routing — not stored or used for training; deleted immediately after processing), retroactive check-in proof photos, health profile data, fitness preferences | | Anthropic (Claude) | Workout and check-in history import, movement analysis and coach chat | Uploaded files and text (images, PDFs, spreadsheets), camera frames during movement analysis and messages to the coach. Anthropic does not use this data to train models and may keep it for up to 30 days to detect abuse | | Google Gemini | Video workout import and some file formats | Uploaded videos and files for exercise extraction, deleted after processing | | PostHog | Product analytics (website and mobile apps) | Usage events and device/app metadata associated with your account identifier, hosted in the United States. No health data, photos, or workout content | | Google Analytics | Usage analytics | Anonymized usage data, device information | | Meta (Facebook Pixel and Conversions API) | Advertising and conversion attribution | Event data and device identifiers. For conversion matching, we send SHA-256 hashed identifiers (email, phone, name, gender, country, and your Fitless account identifier). Hashing prevents the data from being read directly but allows Meta to match it against its own accounts. The IP address and browser user agent accompany the request unhashed, because Meta's API requires them. We send this data only if you accept marketing cookies | | Expo | Push notification delivery (mobile app) | Device push token, notification content | | Resend | Transactional emails | Email address, name |

AI Platforms You Use

If you use the Fitless plugin in ChatGPT or Claude, we return the generated plan to the conversation, at your request. OpenAI and Anthropic receive that content as independent controllers and handle it under their own policies. We do not send them the pain regions.

Legal Requirements

We may disclose your information if required by law, court order, or government request, or to protect the rights, property, or safety of Fitless, our users, or others.

Business Transfers

If Fitless is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

With Your Consent

We may share your information for other purposes with your explicit consent.

Health Data Protections

We commit to the following protections regarding your health data:

  • No Insurance Sharing: We will NEVER share, sell, or provide your health data, body scan results, or fitness information to health insurance companies, life insurance companies, or any insurance-related entities.
  • No Employment Decisions: We will NEVER share your health data with employers or use it for employment-related decisions.
  • No Discrimination: Your health data will never be used to discriminate against you in any way.
  • No Third-Party Health Profiling: We will not sell or license your health data to third parties for profiling, targeting, or any purpose other than providing our Services.
  • No Training on Your Images or Health Data: We do not use your body scan images or identifiable health data to train AI models — the images are deleted immediately after analysis and never retained. Any use of data to improve our models is limited to fully anonymized, non-image telemetry that cannot be traced back to you individually; anything beyond that would require your separate, opt-in consent.

5. Third-Party Services

Our Services integrate with third-party platforms. These providers have their own privacy policies:

We encourage you to review these policies to understand how they handle your data.

6. Data Retention

We retain your data for as long as necessary to provide our Services and fulfill the purposes described in this policy:

| Data Type | Retention Period | |-----------|------------------| | Body scan images | Deleted immediately after analysis; an hourly automated sweep removes anything older than 2 hours. Never stored in our database | | Photos sent for progress comparison | Never written to storage. They exist only for the duration of the analysis request and are discarded when it ends | | Local copy of your scans | Stays on your device, not with us. Deleted when you sign out, delete your account, or delete the scan from the app | | Account information | Until you delete your account | | Health profile | Until you delete your account | | Workout history | Until you delete your account | | Menstrual cycle data | For as long as tracking is on. Deleted as soon as you use "Delete all cycle data" in settings, and on account deletion | | Supplement and hydration entries | Until you delete your account | | Product link taps (Achados) | Until you delete your account | | Product review photos | Public for as long as they exist. Removed from our storage on account deletion | | Check-in photos | Private storage, until you delete your account | | Feedback attachments | Private storage, until you delete your account. The temporary links sent to support expire after 7 days | | Garmin watch authorization | Until you remove the app from the watch or delete your account | | Plugin plans in ChatGPT and Claude | Up to 30 days, deleted automatically if not saved to an account. Failed requests: up to 7 days. Once saved, the plan moves to the account and the plugin copy is deleted; only the record of origin (platform, dates, and status) and of the consents remains, until the account is deleted | | Payment and subscription records | 7 years (legal/tax requirements) | | Support communications | 3 years | | Analytics data | Associated with your account for as long as it exists; on account deletion, we request deletion of your analytics identity and events in PostHog. Aggregated, anonymized statistics may be retained |

When you delete your account, we delete or anonymize your personal information on our servers within 30 days, except where we are required to retain it for legal purposes. Our encrypted backups are replaced on a rolling basis, and the oldest ones are gone within 6 months; until then, they are used only to restore the service after a disaster. We also keep the record of the consents you gave (purpose, version, date, and email) to show that the processing was lawful, and payment and tax records for as long as the law requires.

7. Data Security

We implement industry-standard security measures to protect your information:

  • Encryption: All connections use encryption in transit (TLS). Backups are encrypted before they leave our servers.
  • Access controls: Strict access controls limit who can access your data.
  • Infrastructure: Our servers are in a Contabo data center in the United States, with access restricted to our technical team.
  • Regular audits: We regularly review and update our security practices.
  • Row-Level Security: Database access is restricted so users can only access their own data.

However, no method of transmission over the Internet is 100% secure. If you discover a security vulnerability, please report it immediately to support@fitless.ai.

Data Breach Notification

If we become aware of a security incident that compromises your personal data and is likely to create risk or relevant harm to you, we will:

  • Notify the competent authority within the timeframe required by applicable law. In Brazil, we notify the Agência Nacional de Proteção de Dados (ANPD) and you within 3 business days of learning that the incident affected personal data (ANPD Resolution 15/2024). In the United States, we notify you within 60 days of discovery, or sooner if your State's law requires; and
  • Notify affected users without undue delay, in plain language, describing the nature of the incident, the data involved, the risks, the steps we have taken, and what you can do, with a contact for questions.

We maintain an internal incident-response process to detect, contain, and remediate security incidents.

8. Your Rights and Choices

Depending on your location, you may have the following rights:

For All Users

  • Access: Request a copy of your personal data.
  • Correction: Update or correct inaccurate information.
  • Deletion: Request deletion of your account and personal data.
  • Opt-out of marketing: Unsubscribe from promotional emails.
  • Data portability: Request your data in a portable format.

For EU/EEA Residents (GDPR)

  • Right to object to processing based on legitimate interests.
  • Right to restrict processing in certain circumstances.
  • Right to lodge a complaint with a supervisory authority.
  • Right to withdraw consent at any time.

For Brazilian Residents (LGPD)

You may request, free of charge, by writing to privacy@fitless.ai: (i) confirmation that we process your data; (ii) access; (iii) correction; (iv) anonymization, blocking, or deletion of data that is unnecessary, excessive, or processed in breach of the LGPD; (v) portability; (vi) deletion of data processed on the basis of consent; (vii) information about whom we share your data with; (viii) information about the possibility of not consenting and its consequences; (ix) withdrawal of consent; (x) objection to processing based on another legal basis, such as legitimate interest; and (xi) review of decisions made solely by automated processing. You can also delete your account in the app's Settings.

We confirm whether we process your data and give simplified access immediately, and we send the complete statement within 15 days of the request (LGPD, art. 19). We may ask for minimal information to confirm your identity. You may also petition the Agência Nacional de Proteção de Dados (ANPD).

For California Residents (CCPA)

  • Right to know what personal information is collected and disclosed.
  • Right to delete personal information.
  • Right to opt out of the sale or sharing of personal information. We do not sell your data for money. However, when you accept marketing cookies, we send identifiers to Meta for conversion attribution, and California law treats that as "sharing" for cross-context behavioral advertising. To opt out, choose "Essential only" in the cookie notice, or clear the site's cookies so the notice reappears and you can change your choice. No health data, body imagery, or cycle data is ever sent to advertising platforms.
  • Right to non-discrimination for exercising privacy rights.

For United States Residents

  • Whatever State you live in, you may ask to access, correct, delete, or receive a portable copy of your personal data, and you may opt out of targeted advertising, of any sale of personal data, and of profiling that produces legal or similarly significant effects. We do not sell personal data for money, and we do not use your data for profiling with such effects.
  • Send requests to privacy@fitless.ai, directly or through an authorized agent. We respond within 45 days, and we never discriminate against anyone for using these rights.
  • Appeals: if we deny your request, reply to our answer with the subject "Appeal" within 60 days. We decide within 60 days and explain in writing. If we deny your appeal, you may contact your State Attorney General.
  • Sensitive data: we process sensitive data, including health data, only with your consent. We do not use it for advertising, we do not sell it, and we do not use your personal data to train large language models.
  • Consumer health data: residents of Washington, Nevada, and other States with a consumer health data law are also covered by our Consumer Health Data Privacy Policy.

How to Exercise Your Rights

You can exercise many of these rights through your account settings. For other requests, contact us at privacy@fitless.ai. We will respond within 30 days (or sooner if required by law). We may need to verify your identity before processing your request.

9. International Data Transfers

Fitless operates globally. Your information may be transferred to and processed in countries other than your own, including Brazil, the United States, and countries within the European Economic Area. For example, product analytics data is processed by PostHog on cloud infrastructure hosted in the United States.

Our servers and database are located in the United States. Backups, encrypted before upload, are stored in Europe.

When we transfer data internationally, we ensure appropriate safeguards are in place:

  • Standard Contractual Clauses (SCCs) approved by the European Commission.
  • For Brazilian users, transfer mechanisms recognized by the LGPD (Art. 33), including contractual safeguards with our service providers.
  • Compliance with applicable data protection laws in each jurisdiction.
  • Plugin in ChatGPT and Claude: the plan returned to the conversation goes to OpenAI or Anthropic, in the United States, because this is necessary to provide the service you asked for (LGPD Art. 33, IX). The pain regions are processed in the United States with your specific consent, given in the plugin card after you are informed of the international nature of the transfer (LGPD Art. 33, VIII).

10. Children's Privacy

Our Services are not intended for anyone under 18 years of age. We do not knowingly collect personal information from anyone under 18. The app and the website ask for a date of birth and block access for anyone under 18, and the plugin in ChatGPT and Claude does not generate a plan for anyone who gives an age under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at support@fitless.ai. We will promptly delete such information.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

  • Posting the updated policy on our website with a new "Last updated" date.
  • Sending you an email notification (for significant changes).

For minor updates, your continued use of the Services constitutes acceptance. For any change that materially expands how we process your personal data — especially sensitive or health data — we will obtain your fresh, affirmative consent before that change applies to you.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

OPALLOO INOVACOES LTDA

Avenida Brigadeiro Faria Lima, 1811 - Cj 115 Jardim America - CEP 01452-001 Sao Paulo - SP, Brazil

CNPJ: 53.284.020/0001-06

Email: support@fitless.ai

Data Protection Officer (DPO): privacy@fitless.ai

For Brazilian residents, you also have the right to lodge a complaint with the Agência Nacional de Proteção de Dados (ANPD) (gov.br/anpd).

For EU/EEA residents, you have the right to lodge a complaint with your local data protection authority if you believe we have not addressed your concerns adequately.

This Privacy Policy is available in multiple languages. For consumers resident in Brazil, the Portuguese version governs. For all other users, in case of any discrepancy the English version shall prevail.