Privacy Policy

Last updated: October 20, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Application refers to Amby, the coaching application provided by the Company, including the Amby iOS app and the Amby web app at https://app.tryamby.com.
  • Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
  • CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Amby Health Inc..
  • Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the State of California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State of California who is outside the State for a temporary or transitory purpose.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, used for purposes such as keeping You signed in.
  • Country refers to: California, United States
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
  • Personal Data is any information that relates to an identified or identifiable individual.

    For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

  • Service refers to the Application, the Website, and the coaching conversations You have with Amby by text message (SMS or iMessage).
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to Amby, accessible from https://www.tryamby.com
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. This includes:

  • Your mobile phone number. You sign in with a code We send to it, and Your coaching happens over text messages to that number.
  • Your name.
  • Your email address, if You add one to Your Account or signed up with a Google account.
  • Your training goal and any target race or event, Your preferred units, Your time zone, and when You would like to receive coaching messages.
  • Optionally, Your sex, date of birth, height, and weight, which We use to personalize coaching and estimates such as calories burned.
  • Usage Data.

Your Messages

Amby coaches You by text message (SMS or iMessage). We store the messages You exchange with Your coach, including any photos, audio, or other files You send, so that Your coach can reply and keep track of Your training over time.

Health and Fitness Data

Amby is a coaching service, so the Service collects health and fitness information about You. This includes the training, activity, sleep, and recovery data You choose to share by connecting a third-party service or device, and anything You tell Your coach directly in conversation — for example how a session felt, an injury, or how You slept.

The services You can connect include Apple Health, Garmin Connect™, Strava, WHOOP, Oura, Fitbit, Google, COROS, Ultrahuman, and Hevy. Depending on the service and the permissions You grant, this data can include workouts (type, duration, distance, pace, speed, power, heart rate, and elevation), daily activity (steps and calories), heart rate, resting heart rate, heart rate variability, sleep, body measurements (weight, body mass index, body fat, and lean body mass), VO2 max, blood oxygen, respiratory rate, body temperature, menstrual cycle data, and nutrition (calories, protein, carbohydrates, fat, fibre, sugar, sodium, and water). Amby only reads from Apple Health and never writes to it.

Workouts recorded with GPS can include the route You took, which is precise location information. We do not otherwise access Your device's location.

You choose which services to connect, and You can disconnect them at any time in the Amby app or web app. Where a connected service has its own disclosure requirements, the specifics are set out separately below — see the Garmin Connect data and WHOOP data sections for data received from Garmin and WHOOP.

We treat health and fitness data as sensitive personal information. We use it to provide coaching to You and for no other purpose. We do not use it for advertising, and we do not sell, rent, or license it. Our Consumer Health Data Privacy Policy describes how We handle consumer health data and how to exercise Your rights over it, including under Washington's My Health My Data Act.

Calendar Data

If You choose to connect Google Calendar, Amby reads the list of Your calendars and the times You are busy on the calendars You select, so it can suggest when to train. With Your approval, Amby can also create and update workout events on Your calendar. Amby can only change events it created. It does not read the titles or details of Your other events.

Amby's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. You can disconnect Google Calendar at any time in the Amby web app or from Your Google Account settings.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device. We use one third-party product analytics tool, PostHog, to collect Usage Data on the Website at tryamby.com and in the sign-up flow: which pages were visited, which buttons were used, and where people stop signing up. It is not used anywhere Your health or coaching data is shown, it never receives Your name, email address, phone number, goal, or any health or fitness data, and We do not use advertising tools at all.

Cookies

The Amby web app uses Cookies that are strictly necessary for it to work. They are set and read only by Us. They keep You signed in, keep You on the right step while You sign up, and remember a choice You make for Your session, such as which view to show. Some last only for Your browser session and some persist for longer. If You block these Cookies in Your browser, You will not be able to sign in to the web app.

The Website at tryamby.com and the sign-up flow also set first-party analytics Cookies for PostHog, the product analytics tool described under "Usage Data". They hold a randomly generated identifier so that two page visits can be counted as one visit; they carry no name, email address, phone number, or health or fitness data. Blocking them does not stop You using the Website or signing up.

We do not use advertising or tracking Cookies, web beacons, or pixels, and We do not allow any Cookie We set to be read by an advertising network.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • To coach You: to send You coaching messages by text, including check-ins that Amby starts on its own at the times and on the topics You have chosen, and to reply to Your messages. You can turn each type of coaching message off in Your settings.
  • To contact You: to send You sign-in codes and to contact You by text message or email about Your Account, changes to the Service, or security, when necessary or reasonable.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • To improve the Service: authorized members of the Amby team may review conversations and training data to support You, check the quality and safety of coaching, and find and fix problems. We may also analyze how the Service is used in order to improve it. We do not use Your health and fitness data for marketing.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with the Service Providers listed under "Service Providers We Use" below, so that they can host the Service, operate connections to services You have linked, generate coaching responses, and deliver messages to You. They act on Our instructions and may not use Your information for their own purposes.
  • With services You connect: when You connect a service such as Google Calendar, We send it what is needed to do what You asked, for example a workout event You approved adding to Your calendar.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company retains Your Personal Data for as long as Your Account exists, because Your training history, messages, and coaching notes are what Your coach works from. When You delete Your Account, We delete it as described under "Delete Your Personal Data" below. We may retain Personal Data for longer where We are required to by law, or to resolve disputes and enforce our agreements.

When You disconnect a connected service, We stop receiving new data from it. The data We already received stays in Your training history, so Your coach can still refer to it, unless You ask Us to delete it. To request deletion, contact Us at the address below.

The Company also retains Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

You can delete Your Account at any time from Settings in the Amby iOS app or the Amby web app. Deletion takes effect immediately and cannot be undone. It unlinks Your phone number, disconnects Your connected services, and permanently deletes Your profile, training history, health and fitness data, plans, uploaded files, and conversation with Amby.

You may also update Your profile information at any time in Your account settings, and You may contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so. For example, We keep security logs and records of actions Our team took, with the link to Your Account removed. Our Service Providers may also keep copies for a limited time under their own retention schedules before deleting them.

Your Rights and Choices

Wherever You live, You can:

  • see and update Your profile, units, time zone, and message settings in the Amby app or web app;
  • turn off any type of coaching message in Your settings;
  • withdraw Your permission for Us to send Your data to Our AI provider in Settings, which turns coaching off (see "How We Use AI");
  • disconnect any connected service, and ask Us to delete the data We received from it;
  • delete Your Account in Settings; and
  • ask Us for a copy of the personal information We hold about You, or to correct or delete it, by emailing contact@amby.health.

We may need to confirm that a request comes from You before acting on it, and We may decline a request where the law allows, for example where fulfilling it would affect someone else's rights. California residents have additional rights, described below. Rights over consumer health data are described in Our Consumer Health Data Privacy Policy.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

How We Use AI

Amby's coaching messages are written with the help of AI. To do that, We send Your messages and the health and fitness data Your coaching needs, such as workouts, sleep, and recovery, to Our AI provider, OpenAI. We also use OpenAI to transcribe audio and read images You send, and to organize coaching notes so Your coach can recall them later.

We ask for Your permission before We send Your data to Our AI provider. You can withdraw that permission at any time in Settings. Because Amby cannot coach without AI, withdrawing turns coaching off: Amby stops replying and stops sending You messages until You allow it again.

These requests are made under API terms that prohibit OpenAI from using Your data to train or improve its models. OpenAI may keep this data for a limited period, typically up to 30 days, to operate its service and monitor for abuse.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Access to athlete data within Amby is restricted to authorized members of the Amby team.

Coaching happens by text message. Messages sent by SMS travel over mobile carrier networks, which do not encrypt them the way the Amby app and website do, so avoid sending anything by text that You would not want a carrier to be able to see.

Garmin Connect data

If you choose to connect your Garmin Connect™ account, Amby receives data from Garmin's Health API and Activity API through Garmin's authorized developer program. This includes activity summaries (type, duration, distance, pace, power, heart rate, elevation, training effect), daily wellness data (steps, resting heart rate, heart rate variability, stress, Body Battery™, sleep stages and scores, respiration, VO2 max and related fitness metrics), and the model of the Garmin device that recorded it.

How we use it. Garmin data is used solely to provide you with personalized coaching: reviewing your workouts, assessing recovery and readiness, adjusting your training plan, and sending you coaching messages. We do not use Garmin data for advertising, and we do not sell, rent, or license it to anyone.

Who processes it. Amby receives Garmin data directly from Garmin, with no intermediary. It is then processed by a small number of service providers acting under contract on our behalf and only to deliver the Amby service:

  • our cloud hosting and database providers (data stored in the United States; our database provider encrypts it at rest, and it is encrypted in transit between Amby and these providers);
  • our large language model (AI) provider, which receives the portions of your Garmin data needed to generate a coaching response. These requests are made under API terms that prohibit the provider from using your data to train or improve their models.

We will identify any of these providers by name on request — contact us at the address at the end of this policy.

Amby does not use Garmin data to train machine learning models, and does not permit its providers to do so.

Storage and retention. Garmin data is kept for as long as your Amby account exists. If you disconnect Garmin (in Garmin Connect, or in the Amby app or web app), we stop receiving data immediately. The Garmin data we already received stays in your training history unless you ask us to delete it: email contact@amby.health and we will delete your Garmin-sourced data within 30 days of your request. Deleting your Amby account deletes it as well.

Your controls. You choose which data types to share on Garmin's consent screen and can change or revoke that permission at any time in Garmin Connect. Garmin data shown in Amby is always attributed to Garmin and to your device.

Garmin, Garmin Connect and Body Battery are trademarks of Garmin Ltd. or its subsidiaries.

WHOOP data

If you choose to connect your WHOOP account, Amby receives data from the WHOOP API through our health data integration provider. You sign in to WHOOP directly and approve each category of data yourself on WHOOP's own authorization screen. Amby never sees, receives, or stores your WHOOP username, password, or credentials.

What we receive. Depending on the permissions you grant: Sleep (Sleep Performance, Sleep Consistency, Sleep Efficiency, sleep stage durations, Respiratory Rate, and Blood Oxygen), Recovery (Recovery Score, Heart Rate Variability, Resting Heart Rate, and Skin Temperature), Cycles (Day Strain and Energy Burned), Workouts (Activity Strain, Activity Type, average and maximum heart rate, and heart rate zone durations), Body Measurements (maximum heart rate, height, and weight), and Profile (your name and email).

How we use it. WHOOP data is used solely to provide you with personalized coaching: your morning check-in, notes before and after training, your weekly review, and the coaching messages your coach sends you. We do not use WHOOP data for advertising, and we do not sell, rent, lease, license, or sublicense it to anyone. We do not show your WHOOP data to any other member, coach, team, or third party without your explicit opt-in consent — this applies to team and group programmes as well as to individuals.

When we refer to a WHOOP metric, we present it under WHOOP's own name and attribute it to WHOOP — for example, "based on your WHOOP Recovery".

Who processes it. WHOOP data is processed by a small number of service providers acting under contract on our behalf and only to deliver the Amby service:

  • a health data integration provider, which operates the technical connection to WHOOP and normalizes the data;
  • our cloud hosting and database providers (data stored in the United States; our database provider encrypts it at rest, and it is encrypted in transit between Amby and these providers);
  • our large language model (AI) provider, OpenAI, which receives the portions of your WHOOP data needed to generate a coaching response. These requests are made under API terms that prohibit the provider from using your data to train or improve their models.

We will identify any of these providers by name on request — contact us at the address at the end of this policy.

Amby does not use WHOOP data to create, develop, test, train, fine-tune, or improve any large language model or any other machine learning or artificial intelligence model, application, or system, and does not permit its providers to do so.

Storage and retention. WHOOP data is kept for as long as your Amby account exists. If you disconnect WHOOP (in WHOOP, or in the Amby app or web app), we stop receiving new data immediately. The WHOOP data we already received stays in your training history unless you ask us to delete it: email contact@amby.health and we will delete your WHOOP-sourced data within 30 days of your request. Deleting your Amby account deletes it as well. If Amby's access to the WHOOP API ends, we delete the WHOOP data we hold.

Your controls. You choose which data types to share on WHOOP's authorization screen, and you can revoke that permission at any time in WHOOP or by disconnecting WHOOP in the Amby app or web app. You can request a copy of the WHOOP data we hold for you at any time at contact@amby.health.

Not medical advice. Amby provides general training, fueling, and recovery coaching. It does not diagnose, does not provide medical or other professional advice, and is not a medical device.

Security. Your WHOOP data is encrypted in transit and at rest. If we become aware of unauthorized access to it, we will notify you as required by law and notify WHOOP.

WHOOP and the WHOOP logo are trademarks of Whoop, Inc. Amby uses the WHOOP API to access your data with your permission, and is not endorsed by or affiliated with Whoop, Inc.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. They process it on Our behalf, under contract with Us, and only to provide the Service.

Service Providers We Use

We work with a small number of Service Providers. They process personal information only on Our instructions, under contract, and only to deliver the Service. They are not permitted to use it for their own purposes. By category, they are:

  • Cloud hosting and database providers, which store Your account and training data in the United States. Our database provider encrypts it at rest, and it is encrypted in transit between the Service and these providers.
  • Health and fitness data integration providers, which operate the technical connections to the services and devices You choose to link, other than Garmin Connect, which Amby connects to directly.
  • Our large language model (AI) provider, OpenAI, which receives the portions of Your data needed to generate a coaching response, as described under "How We Use AI". These requests are made under API terms that prohibit the provider from using Your data to train or improve their models.
  • A calendar integration provider, which operates the connection to Google Calendar if You choose to connect it.
  • Messaging providers, which deliver the text messages Your coach sends and receives, and the sign-in codes We send to Your phone.
  • Our product analytics provider, PostHog, which receives Usage Data from the Website and the sign-up flow only, as described under "Usage Data". It receives no health or fitness data and nothing that identifies You by name, email address, or phone number.

Where a service You connect requires Us to identify its processors by name, We do so in the section covering that service — see Garmin Connect data and WHOOP data.

We do not use Your data to train machine learning models, and we do not permit these providers to do so.

We do not use advertising, remarketing, or interest-based advertising services, and We do not use third-party analytics services that build advertising profiles from Your use of the Service. We do not currently charge for the Service and do not collect payment card details.

If You sign in with a Google account, Google shares Your name and email address with Us according to Your Google account settings.

You may contact Us at the address below for the current list of Service Providers We use.

CCPA/CPRA Privacy Notice (California Privacy Rights)

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

  • Category A: Identifiers.

    Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

    Collected: Yes.

  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

    Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

    Collected: Yes.

  • Category C: Protected classification characteristics under California or federal law.

    Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

    Collected: Yes, to the extent You share it. For example, Your age or sex, or an injury or medical condition You tell Your coach about.

  • Category D: Commercial information.

    Examples: Records and history of products or services purchased or considered.

    Collected: No. The Service is currently free and We do not process purchases.

  • Category E: Biometric information.

    Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

    Collected: Yes. We collect sleep, health, and exercise data, such as heart rate, heart rate variability, sleep, and workouts, from the services You connect and from what You tell Your coach. We do not collect fingerprints, faceprints, voiceprints, or iris or retina scans.

  • Category F: Internet or other similar network activity.

    Examples: Interaction with our Service or advertisement.

    Collected: Yes.

  • Category G: Geolocation data.

    Examples: Physical location or movements.

    Collected: Yes. Workouts You sync from connected services and devices can include the GPS route of the activity. We also store Your time zone. We do not track Your device's location outside of the workout data You share.

  • Category H: Sensory data.

    Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

    Collected: Yes, only if You send photos, audio, or other media to Your coach in a message.

  • Category I: Professional or employment-related information.

    Examples: Current or past job history or performance evaluations.

    Collected: No.

  • Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

    Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

    Collected: No.

  • Category K: Inferences drawn from other personal information.

    Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

    Collected: Yes. To coach You, We keep notes and a profile of Your goals, preferences, fitness, training history, and how You respond to training.

  • Category L: Sensitive personal information.

    Examples: Account login credentials, precise geolocation, and personal information collected and analyzed concerning a consumer's health.

    Collected: Yes. This includes Your health and fitness data and the precise location contained in workout routes. We use sensitive personal information only to provide the Service to You.

Under CCPA/CPRA, personal information does not include:

  • Publicly available information from government records
  • Deidentified or aggregated consumer information
  • Information excluded from the CCPA/CPRA's scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from You. For example, from the forms You complete on our Service, the messages You send Your coach, and the preferences You express or provide through our Service.
  • Indirectly from You. For example, from observing Your activity on our Service.
  • Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
  • From services You connect. For example, Apple Health and the health, fitness, and calendar services You choose to link, either directly or through the providers listed under "Service Providers We Use".

Use of Personal Information

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:

  • To operate our Service and provide You with Our Service.
  • To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
  • To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.
  • For internal administrative and auditing purposes.
  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes, We will update this Privacy Policy.

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category C: Protected classification characteristics under California or federal law
  • Category E: Biometric information (sleep, health, and exercise data)
  • Category F: Internet or other similar network activity
  • Category G: Geolocation data
  • Category H: Sensory data
  • Category K: Inferences drawn from other personal information
  • Category L: Sensitive personal information

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Share of Personal Information

We may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:

  • Service Providers, as listed under "Service Providers We Use" above
  • Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Sale of Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell Your personal information, and We have not sold it in the last twelve (12) months. We also do not share it for cross-context behavioral advertising, as "share" is defined by the CCPA/CPRA. We disclose personal information to Service Providers only for the business purposes described in this Privacy Policy, under contracts that forbid them from using it for their own purposes.

Sale of Personal Information of Minors Under 16 Years of Age

The Service is intended only for people aged 18 or older. We do not knowingly collect personal information from anyone under 18, and We do not sell the personal information of any Consumer, including Consumers under 16 years of age.

If You have reason to believe that someone under 18 has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
    • The categories of personal information We collected about You
    • The categories of sources for the personal information We collected about You
    • Our business or commercial purposes for collecting or selling that personal information
    • The categories of third parties with whom We share that personal information
    • The specific pieces of personal information We collected about You
    • If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
      • The categories of personal information categories sold
      • The categories of personal information categories disclosed
  • The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request, please see the "Do Not Sell My Personal Information" section or contact Us.
  • The right to correct Personal Data. You have the right to correct or rectify any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct our Service Providers to correct) Your personal information, unless an exception applies.
  • The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about You, unless an exception applies. To submit, please see the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact Us.
  • The right to delete Personal Data. You have the right to request the deletion of Your Personal Data under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
    • Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
    • Denying goods or services to You
    • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
    • Providing a different level or quality of goods or services to You
    • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA/CPRA Data Protection Rights

Please see the "Do Not Sell My Personal Information" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.

Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

  • Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
  • Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if We cannot:

  • Verify Your identity or authority to make the request
  • And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration.

We do not sell Your personal information, so there is nothing for You to opt out of. We do not use advertising or remarketing services, and none of Our Service Providers use technology on the Service that sells personal information as defined by the CCPA/CPRA. If this ever changes, We will update this Privacy Policy and provide a way to opt out before the change takes effect.

You may contact Us at any time with questions about how Your personal information is used.

Limit the Use or Disclosure of My Sensitive Personal Information

If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such services or goods.

We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how We use Your personal information, please see the "Use of Your Personal Data" section or contact us.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

Children's Privacy

The Service is intended only for people aged 18 or older, as set out in Our Terms and Conditions. We do not knowingly collect Personal Data from anyone under 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under 18, We take steps to remove that information from Our servers.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: