Who is responsible for your data
[LEGAL ENTITY NAME] Kft. ("FitPilot", "we", "us") is the data controller for the personal data described in this policy.
We have not appointed a Data Protection Officer, as we are not required to under Article 37 GDPR.
This policy explains what we collect, why, how long we keep it, and what you can do about it. It applies to the FitPilot app and to thefitpilotapp.com.
The short version
What we collect
3.1 Account data
Email address, password (stored as a hash, never in readable form), account creation date, subscription status, and the language and units you have chosen.
If you sign in with Apple or Google: the identifier and email address that service passes to us. If you use Apple's Hide My Email, we only ever receive the relay address.
3.2 Profile and training data
Age or date of birth, sex, height, training experience level, and equipment you have access to. Your workouts: exercises, sets, reps, loads, effort ratings, rest times, notes, and timestamps. Your programs and progression settings. Calculated values we derive from this, such as estimated one-rep max and volume totals.
3.3 Health data
Body weight and body measurements, if you choose to record them. Injuries and physical limitations you record so that the app can take them into account when suggesting exercises.
Both are optional. You enter them yourself. We do not read data from Apple Health, Google Fit, or any wearable.
Nutrition, supplement, sleep, heart rate, and daily wellbeing tracking are not part of the current release. If we add them, we will update this policy and ask for your consent before processing that data.
Section 4 explains the special rules that apply to health data.
3.4 Community content
Exercise cues, tips, and any other content you post, along with your display name and the time you posted.
3.5 Technical and usage data
Device model, operating system version, app version, language, approximate region derived from IP address, crash reports and diagnostic logs, and product analytics events describing which screens and features you use and when.
3.6 Support correspondence
The content of emails you send us and our replies.
3.7 What we do not collect
Health data and your explicit consent
Two things you can record in FitPilot are health data under Article 9 GDPR: your body weight and measurements, and any injuries or physical limitations you note. Entering them yourself does not change that. Both say something about your physical condition.
Health data gets stronger protection than ordinary personal data. Article 9 prohibits processing it unless a specific condition applies, and the one we rely on is your explicit consent under Article 9(2)(a) GDPR.
- We ask for this consent separately in the app. It is not bundled into accepting the Terms of Service.
- Both features are optional. Workout logging, the exercise database, SmartCoach, and progression all work without them. If you decline, we do not store body weight, measurements, or injury notes, and exercise suggestions will not account for injuries.
- You can withdraw consent at any time in your privacy settings. Withdrawal is as easy as giving it, takes effect going forward, and does not make our earlier processing unlawful.
- If you withdraw consent, we stop processing that category and delete the associated records within [30] days.
Your workout log itself, meaning exercises, sets, reps, and loads, is processed to perform our contract with you. Combined with your age, sex, and height it can still say something about your physical condition, so we protect it to the same standard as the data above.
Why we process your data, and on what legal basis
| What we do | Data used | Legal basis |
|---|---|---|
| Create and run your account | Account data | Performance of a contract, Art. 6(1)(b) |
| Store and sync your workouts across devices | Training data | Performance of a contract, Art. 6(1)(b) |
| Generate SmartCoach messages and progression suggestions | Training data, plus injury notes if you provide them | Contract, Art. 6(1)(b), plus explicit consent, Art. 9(2)(a), for the injury notes |
| Store body weight, measurements, and injury notes | Health data | Explicit consent, Art. 9(2)(a) |
| Show and moderate community content | Community content | Contract, Art. 6(1)(b), and legal obligation under the Digital Services Act, Art. 6(1)(c) |
| Verify your subscription and trial status | Account data, store receipt | Performance of a contract, Art. 6(1)(b) |
| Diagnose crashes and keep the app secure | Technical data | Legitimate interests, Art. 6(1)(f), in providing a working and secure service |
| Understand which features are used, to improve the product | Usage data | Your consent, Art. 6(1)(a) |
| Send service messages such as trial expiry reminders | Email address | Performance of a contract, Art. 6(1)(b) |
| Send marketing emails, if you opt in | Email address | Your consent, Art. 6(1)(a) |
| Answer support requests | Correspondence | Legitimate interests, Art. 6(1)(f), in supporting our users |
| Keep accounting records | Transaction records | Legal obligation, Art. 6(1)(c) |
| Establish or defend legal claims | As relevant | Legitimate interests, Art. 6(1)(f) |
Where we rely on legitimate interests, we have weighed our interest against your rights, and you can object at any time. See Section 11.
Analytics and crash reporting
We use [CRASH REPORTING PROVIDER] to receive crash reports and [ANALYTICS PROVIDER] to understand how the app is used.
Crash reporting runs on the basis of our legitimate interest in shipping an app that works. Crash reports contain device and app state, not your training or health data.
Product analytics runs only if you agree. We ask on first launch and you can change your answer at any time in settings. Analytics events describe actions such as opening a screen or finishing a workout. We do not send your health entries, body measurements, or workout content to the analytics provider.
On iOS, we do not track you across apps or websites owned by other companies, and we do not use the Advertising Identifier.
We do not build advertising profiles, and we do not share data with data brokers or ad networks.
Who we share data with
We share data only with providers who process it on our instructions, under a data processing agreement meeting Article 28 GDPR.
| Provider | What they do | Where |
|---|---|---|
| [HOSTING PROVIDER] | Hosts the app database and backend | [REGION] |
| [CRASH REPORTING PROVIDER] | Crash and error reports | [REGION] |
| [ANALYTICS PROVIDER] | Product analytics | [REGION] |
| [EMAIL PROVIDER] | Sends service and support email | [REGION] |
| [PUSH NOTIFICATION PROVIDER] | Delivers notifications | [REGION] |
| [SUBSCRIPTION PROVIDER] | Verifies subscription status | [REGION] |
Apple and Google act as independent controllers for your purchase, not as our processors. They handle payment and tell us only whether your subscription is active. Their own privacy policies govern what they do with that transaction.
We may also disclose data where the law requires it, for example in response to a valid order from a competent authority, or where necessary to establish, exercise, or defend legal claims. If FitPilot is ever sold or merged, data may transfer to the buyer, and we will tell you before that happens.
We do not sell personal data, and we do not share it for anyone else's marketing.
Transfers outside the EU
We aim to keep data in the European Union.
Where a provider processes data outside the EU or EEA, we rely on one of the safeguards in Chapter V GDPR, normally the European Commission's Standard Contractual Clauses together with an assessment of the destination country, or an adequacy decision where one applies.
You can ask us at support@thefitpilotapp.com which safeguard applies to a specific provider.
How long we keep data
| Data | Retention |
|---|---|
| Account and training data | Until you delete your account |
| Body weight, measurements, and injury notes | Until you delete them, or within [30] days of withdrawing consent |
| Backups | Deleted data disappears from backups within [30] days |
| Community content | Until you delete it or your account, unless we must keep it for a legal reason |
| Crash reports | [90] days |
| Analytics events | [14] months |
| Support correspondence | [2] years after the request is closed |
| Accounting records | 8 years, as required by Hungarian accounting law |
When you delete your account, we remove your personal data within [30] days, except records we are legally required to keep and anything needed for an ongoing legal claim. Community content you posted may remain visible in anonymized form if others have relied on it, unless you ask us to remove it.
Security
We protect your data with encryption in transit, encryption at rest, hashed passwords, access controls limiting who can reach production data, and regular backups.
No system is perfectly secure. If a breach occurs that is likely to result in a high risk to your rights, we will tell you without undue delay, and we will notify the supervisory authority within 72 hours as required by Article 33 GDPR.
Your rights
Under GDPR you have the right to:
You can delete your account directly in the app. To request a copy of your data, or for anything else, email support@thefitpilotapp.com. We respond within one month, extendable by two further months for complex requests, and we will tell you if we need the extension.
We do not charge for these requests unless they are manifestly unfounded or excessive.
Complaints. If you think we have handled your data wrongly, tell us first and we will try to fix it. You also have the right to complain to a supervisory authority. Ours is:
Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH) 1055 Budapest, Falk Miksa utca 9-11.
Postal address: 1363 Budapest, Pf. 9.
Phone: +36 1 391 1400
Email: ugyfelszolgalat@naih.hu
Web: naih.hu
If you live in another EU country, you can complain to your own national authority instead.
Country specific information
Because we are established in Hungary, the GDPR governs how we handle your data no matter where you live. Every right in Section 11 is available to every FitPilot user worldwide, not only to users in Europe. This section adds information that applies in particular countries.
Switzerland
If you are in Switzerland, the Federal Act on Data Protection applies alongside the rights in Section 11. You can complain to the Federal Data Protection and Information Commissioner at edoeb.admin.ch.
California
We do not sell your personal information and we do not share it for cross-context behavioral advertising, as those terms are defined in the California Consumer Privacy Act. We have never done so. There is nothing for you to opt out of, but you can contact us at any time to confirm.
We collect the categories described in Section 3 for the purposes in Section 5, and we retain them for the periods in Section 9. We do not use sensitive personal information to infer characteristics about you.
You have the right to know, delete, and correct your personal information, to opt out of sale or sharing, to limit use of sensitive personal information, and not to be discriminated against for exercising these rights. Exercise them at support@thefitpilotapp.com. You can also use an authorized agent.
Brazil
If you are in Brazil, the Lei Geral de Proteção de Dados applies alongside the rights in Section 11. You can complain to the Autoridade Nacional de Proteção de Dados at gov.br/anpd.
Everywhere else
Your country may give you rights beyond those described here. Contact us at support@thefitpilotapp.com and we will honor any right your local law grants you.
Automated processing
SmartCoach messages and progression suggestions are generated automatically by rules applied to the data you log. They produce coaching messages and training suggestions.
These do not produce legal effects or similarly significant effects on you within the meaning of Article 22 GDPR. They are suggestions in a fitness app, and you decide whether to follow them. We do not use automated processing to make decisions about your access to the Service, your pricing, or anything outside your training.
We do not profile you for advertising.
Children
FitPilot is not for anyone under 16. We do not knowingly collect data from children under 16. This is above the threshold in the US Children's Online Privacy Protection Act and at or above the digital consent age in every EU country.
If you believe a child under 16 has given us data, contact support@thefitpilotapp.com and we will delete it.
Changes to this policy
We will update this policy when our processing changes, for example when we add nutrition, supplement, sleep, or wellbeing tracking.
For material changes we will notify you in the app or by email before they take effect. If a change requires your consent, we will ask for it rather than assume it. The date at the top always shows the current version.
Contact
Questions, requests, or complaints: support@thefitpilotapp.com