Privacy Policy

Effective date: January 11, 2025

Last updated: July 22, 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 and the Fitless mobile application (collectively, the "Services").

By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please do not use our Services.

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. For body scans and AI body analysis, we collect this consent through a dedicated in-app opt-in shown before the feature is used — separately from your general acceptance of these terms — and we record each consent together with its purpose, the policy version, and a timestamp. Providing sensitive data is always optional: you can use the core Services and generate a workout plan without a body scan.

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.
  • 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). We never receive or store your full credit card number.
  • Communications: Messages you send to our support team, feedback, and survey responses.

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.

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, we receive and store limited subscription data from Apple in order to manage your access to paid features:

  • Apple transaction identifiers.
  • The subscription product purchased, its status, and its expiry date.
  • Server notifications (webhook events) from Apple 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) 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 Supabase, 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.

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, encrypted storage bucket accessible only to you and our analysis system.
  3. Analysis: Images are sent to our AI provider (Google Gemini) 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 permanently deletes any body scan image within 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.

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.

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), which does not retain the image or use it to train models.
  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 | | Supabase | Database hosting, authentication, file storage | Account data, health profiles, workout data | | Vercel | Application hosting, content delivery, and file storage | Data in transit, request/access logs, generated files (e.g., PDFs) | | Google Gemini (via OpenRouter) | AI-powered body analysis and workout generation | Body scan images (sent via zero-data-retention routing — not stored or used for training; deleted immediately after processing), health profile data, fitness preferences | | Google Gemini | Workout import processing | Uploaded files (videos, images, PDFs) 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, and gender). Hashing prevents the data from being read directly but allows Meta to match it against its own accounts | | Expo | Push notification delivery (mobile app) | Device push token, notification content | | Resend | Transactional emails | Email address, name |

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; automated backup sweep within 2 hours. Never stored in our database | | Account information | Until you delete your account | | Health profile | Until you delete your account | | Workout history | Until you delete your account | | 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 will delete or anonymize your personal information within 30 days, except where we are required to retain it for legal purposes.

7. Data Security

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

  • Encryption: All data is encrypted in transit (TLS/SSL) and at rest.
  • Access controls: Strict access controls limit who can access your data.
  • Secure infrastructure: We use trusted cloud providers with SOC 2 compliance.
  • 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 — in Brazil, the Autoridade Nacional de Proteção de Dados (ANPD) — within the timeframe required by applicable law (LGPD Art. 48; GDPR Art. 33); and
  • Notify affected users without undue delay where the incident is likely to result in a high risk to your rights, describing the nature of the incident, the data involved, the likely consequences, and the steps we have taken to address it (GDPR Art. 34).

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)

  • Right to confirmation of data processing.
  • Right to anonymization, blocking, or deletion of unnecessary data.
  • Right to information about shared data with third parties.
  • Right to revoke consent.
  • Right to petition the Autoridade Nacional de Proteção de Dados (ANPD) in relation to your data.

For California Residents (CCPA)

  • Right to know what personal information is collected and disclosed.
  • Right to delete personal information.
  • Right to opt-out of sale of personal information (we do not sell your data).
  • Right to non-discrimination for exercising privacy rights.

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.

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.

10. Children's Privacy

Our Services are not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. Users between 16 and 18 years of age may use our Services only with the consent of a parent or legal guardian, as described in our Terms of Use. If you are a parent or guardian and believe your child under 16 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 Autoridade 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.