| Data | Where it lives | Why | Legal basis (GDPR) |
|---|---|---|---|
| Programme, session results, timers, settings, reminders | Your phone only | To run the app | Contract |
| Apple Health data you authorise (workouts, heart rate, steps, sleep, nutrition, weight, waist, glucose) | Your phone only (Apple Health) | Session planning, Fuel, Activity, notifications | Explicit consent (health data is special-category) |
| Camera frames | Processed in memory on your phone; never stored or sent | Rep counting and form feedback | Consent (camera permission) |
| Microphone audio | Transcribed on your phone (Apple speech recognition; may use Apple servers per iOS settings); audio not stored by us | Voice questions to the coach | Consent |
| Coach messages (text) and set summaries | Sent to the AI provider for the reply; FormFlect+ requests pass through our server without being stored | To answer you | Contract |
| Email address (early-access list, support) | Our database (Google Cloud, Sydney region) and our email provider | To tell you about release and reply to you | Consent; you can unsubscribe at any time |
| Purchase records | Apple (App Store) and RevenueCat (entitlement status, anonymous app-user ID) | To unlock what you bought | Contract |
| Crash and diagnostic reports | Apple, if you have sharing enabled; our own logs contain no personal data | To fix bugs | Legitimate interests |
We do not sell personal information, do not share it for cross-context behavioural advertising, do not use advertising SDKs, and do not profile you for anything other than the coaching you asked for. We do not knowingly collect data from children under 16.
FormFlect is for people aged 16 and over. Fuel’s eating-window (time-restricted eating) features are for adults 18 and over and are hidden for younger users and for anyone who tells us they take diabetes medication, are pregnant or breastfeeding, or have a history of disordered eating. If you are under 16, please do not use the app or give us your email address.
On-device data stays in your country. Our early-access list is stored in Australia. AI requests for FormFlect+ are processed by OpenAI in the United States under standard contractual clauses; with your own key, by the provider you chose. Apple processes purchases under its own policy.
On-device data: until you delete the app or clear it in Settings. Early-access emails: until you unsubscribe or 12 months after launch, whichever is sooner. Coach messages: not retained by us; OpenAI’s API retains inputs for up to 30 days for abuse monitoring and does not train on them.
Wherever you live you can ask us what we hold about you, correct it, delete it, or object to processing; EU/UK users may also lodge a complaint with their supervisory authority, Australians with the OAIC, and Californians may exercise their CCPA rights (we do not sell or share personal information, so there is nothing to opt out of). Email hello@formflect.app; we respond within 30 days.
Health and fitness data is sensitive. We only ever read what you authorise in Apple Health, use it solely to provide the features you see, never transmit it to our servers, and never share it with third parties. FormFlect is not a medical device and does not provide medical advice.
We will post changes here with a new effective date, and tell you in the app if they are material.