Privacy and Health Data Notice

About this notice

This notice explains what personal information Bodywise Coach collects, why we use it, how it is protected, how long we keep it, who may receive it and the rights you have over it.

Bodywise Coach is operated by Chris Mann trading as Bodywise Coach, a sole trader.

Postal address: 4 Birds Garden Cottage, Stowmarket, Suffolk, IP14 6AS, United Kingdom

Privacy and data-rights enquiries: privacy@bodywise.io

General support: support@bodywise.io

Security concerns: security@bodywise.io

Legal enquiries: legal@bodywise.io

Chris Mann trading as Bodywise Coach is the controller of the personal information used to operate Bodywise Coach, except where another organisation acts independently for its own processing, such as Apple or Paddle in relation to parts of their payment services.

Bodywise Coach is for adults aged 18 or over.

What information we collect

Depending on the features you use, we may process:

• Account and profile information, such as your email address, display name, account settings, units, time zone and other account preferences.
• Age and eligibility information, including your date of birth and records needed to confirm that you meet the 18+ requirement.
• Training information, including your training history, programme, exercises, sessions, sets, repetitions, loads, effort ratings, substitutions, preferences, notes and performance.
• Nutrition information, including calorie and macronutrient targets, meal plans, food logs, food preferences, dietary requirements, allergies and intolerances.
• Health, safety and body information, including bodyweight, measurements, body-composition information, DEXA information or reports you choose to provide, injuries or health matters you choose to disclose, pain or discomfort, recovery, sleep, stress, mood, appetite, energy and safety-screening information.
• PAR-Q and safety information, including screening answers, safety flags, relevant acknowledgements, warnings and information you provide when Bodywise needs to respond safely.
• Progress information, including measurements, training progress, nutrition progress and progress photographs where you choose to upload them.
• Coach information, including messages, questions, notes and relevant Bodywise information used to provide the virtual Coach experience.
• Files you upload, such as profile images, progress photographs and body-composition reports.
• Subscription information, such as subscription provider, product identifier, transaction/subscription reference, entitlement status and relevant purchase, renewal, expiry, cancellation, refund or revocation information. Bodywise does not need to store your full card number or CVV.
• Support and rights-request information, including correspondence and records of requests to access, correct, export or delete information.
• Technical and security information, such as authentication/session information, security events, error information and limited diagnostic information needed to operate and protect the service.
• Pre-sign-up calculator information, where you choose to use a calculator before opening an account, such as email address and the information required to calculate the requested result.
• Consent and preference records, including when and how you accepted Terms, gave or withdrew health-data consent, chose analytics preferences or opted into or out of marketing.

Where the information comes from

Most information comes directly from you.

Some information is created by Bodywise from what you provide, for example calculated nutrition targets, programme decisions, progress calculations and safety or coaching outputs.

A report produced elsewhere, such as a DEXA report, may contain information originating from another organisation, but Bodywise receives it from you when you choose to enter or upload it.

Bodywise does not currently read health information directly from Apple HealthKit, wearables, healthcare providers or other connected health apps.

If connected health-data imports are introduced later, the privacy, consent and regulatory position will be reviewed before that functionality is released.

Health information and explicit consent

Much of the information Bodywise uses is information concerning your health and therefore receives additional protection under data-protection law.

For the ordinary personalised fitness, nutrition, progress and coaching service, Bodywise asks for separate explicit health-data consent.

That consent is not bundled into acceptance of the Terms and is not pre-selected for you.

You may withdraw health-data consent at any time through the privacy controls available in Bodywise or by contacting privacy@bodywise.io.

Withdrawing health-data consent stops future processing that depends on that consent. This means personalised training, nutrition, progress or coaching features that require health information may no longer work.

Withdrawal does not make earlier lawful processing unlawful.

Withdrawal also does not necessarily require Bodywise to erase information that must lawfully be retained for another distinct purpose, such as narrowly necessary evidence for establishing, exercising or defending a legal claim. Any such retention is dealt with separately below and is not treated as continued consent-based coaching.

Why we use personal information

We use information to:

• create and manage your account;
• determine eligibility to use an 18+ service;
• create and adapt your training programme;
• calculate and adapt nutrition targets;
• create meal plans and shopping information;
• record workouts, food, progress and other information you choose to track;
• provide the virtual Coach;
• respond appropriately to safety information;
• provide, verify and manage subscription entitlements;
• respond to support enquiries;
• fulfil privacy and data-rights requests;
• protect accounts, investigate misuse and secure the service;
• diagnose and fix technical faults;
• maintain necessary business, accounting, legal and compliance records;
• honour marketing opt-outs;
• provide calculator results before registration;
• measure use of Bodywise where optional analytics consent has been given.

Our principal legal bases

The exact legal basis depends on the processing and the law that applies to you.

For ordinary account and service administration, we generally process information because it is necessary to provide the service you have requested or to take steps at your request before entering into the contract.

For ordinary personalised processing of health information, we rely on your explicit consent where that condition is required.

For account security, fraud prevention, service integrity and necessary administration, we may rely on our legitimate interests where those interests are not overridden by your rights.

Where we must retain information to comply with a legal obligation, we rely on that legal obligation.

Where narrowly necessary health or safety evidence must be retained for the establishment, exercise or defence of legal claims, that processing is separate from ordinary coaching and may rely on the legal-claims condition applicable to special-category information together with the appropriate ordinary lawful basis.

Where vital interests genuinely apply, they may provide a lawful basis for an exceptional safety disclosure or action.

Marketing and optional analytics are treated separately as explained below.

How Bodywise makes plans and recommendations

Bodywise uses defined calculations and decision rules to create and adjust aspects of training and nutrition.

The virtual Coach can use an external AI/model service to help understand your message and relevant Bodywise context and produce a conversational response.

The AI model is not a human coach, doctor or clinician.

The Coach does not replace medical advice.

Bodywise's controlled rules and safety architecture remain responsible for plan and safety decisions where the product is designed that way; the external language model is not given unrestricted authority to make medical or safety decisions.

Bodywise does not use these automated processes to make decisions that produce legal or similarly significant effects on you.

Service providers and other organisations

Bodywise relies on third parties to operate parts of the service.

These may include providers of:

• cloud hosting, authentication, database and private storage;
• AI/model infrastructure;
• email delivery and business email;
• website payment processing;
• App Store subscription processing;
• analytics where you have consented;
• security or technical services.

Different provider roles

Different providers may have different legal roles.

For example, Apple processes App Store purchases through its own services and terms.

Paddle acts as Merchant of Record for eligible website purchases and handles the payment relationship for those transactions.

Other technical providers may process information in order to provide services to Bodywise.

We do not describe a provider as acting solely on our instructions unless that relationship has actually been established.

Apple App Store purchases

If you subscribe through the Bodywise Coach iOS app, the transaction is processed through Apple.

Apple handles the App Store payment process under its own terms and privacy practices.

Bodywise receives information needed to recognise and manage your subscription entitlement, such as product and transaction/subscription information, but does not receive your full payment-card details from Apple.

Website purchases through Paddle

Where Bodywise Pro is purchased through the Bodywise website, checkout is provided through Paddle.

Paddle acts as Merchant of Record for those website transactions and handles matters including payment processing, applicable billing and tax administration and transaction documentation under its own terms.

Full card details entered into Paddle's checkout are handled by Paddle and are not stored by Bodywise as raw card credentials.

International processing and transfers

Bodywise is operated from the United Kingdom but uses technology providers that may process information in other countries.

Where data-protection law requires a specific safeguard for an international transfer, Bodywise must use an applicable lawful transfer mechanism or another lawful route.

Provider locations, contractual roles and transfer mechanisms can vary by service and may change. Bodywise maintains internal provider records and does not state a specific hosting country, transfer clause or provider-retention period unless it has been confirmed.

You may contact privacy@bodywise.io for current information about relevant providers and international-processing arrangements.

EEA users

Where EU GDPR applies, Bodywise provides the rights and protections required by that law.

Analytics and device measurement

Non-essential analytics is off until you make an affirmative analytics choice where consent is required.

Rejecting optional analytics must not prevent you from using the core Bodywise service.

You can withdraw or change your analytics choice later.

Withdrawing prevents future optional measurement and Bodywise removes optional device values under its control where the implementation supports that removal.

Withdrawal does not automatically erase historical information already lawfully processed by an external analytics provider unless that provider's applicable controls and law require it.

We do not intentionally send PAR-Q responses, free-text Coach conversations, DEXA values, allergies, injuries, meal logs or equivalent sensitive Bodywise information to analytics providers.

Advertising

Advertising is currently switched off across Bodywise.

Bodywise does not currently show advertising in the app as part of this release.

If advertising is introduced in future, the privacy, consent and advertising architecture must be reviewed before it is activated.

Bodywise health, PAR-Q, injury, allergy, nutrition, DEXA, Coach, workout, progress, mood, stress or equivalent sensitive information must not be used to target advertising.

Bodywise Pro is intended to remain ad-free.

Marketing and service messages

Bodywise may send messages required to operate your account or provide the service, such as security, authentication, payment, safety or important service messages.

Promotional marketing is treated separately.

Where consent is required for marketing, we obtain it separately.

Where local law allows another basis for a commercial message, such as a qualifying existing customer relationship, Bodywise must satisfy that law's conditions and time limits.

Every marketing opt-out is honoured.

Bodywise maintains the minimum suppression information necessary to prevent an address that has opted out from being accidentally added back to marketing.

For recipients in Canada, commercial electronic messages are subject to the applicable CASL requirements, including the relevant consent basis, sender identification and unsubscribe requirements.

Pre-sign-up calculators

If you provide information to a Bodywise calculator before creating an account, we use it to produce the requested result and, where relevant, allow you to continue into account setup.

Submitting a calculator is not marketing consent.

If you do not create an account, unconverted calculator/profile data is retained for no more than 30 days, then deleted unless a distinct lawful purpose genuinely applies.

How long we keep information

We do not apply a single retention period to everything.

Ordinary Bodywise account information

Ordinary operational account information is kept while it is needed to provide your account.

When your account is deleted, ordinary account information is deleted or irreversibly anonymised, subject to the limited exceptions below.

Ordinary data includes normal training, nutrition, progress, Coach, meal-plan, workout, measurement, ordinary DEXA, upload, photograph, preference and setup information.

Legal and safety evidence

Bodywise may retain a narrow and restricted legal/safety evidence record for up to 10 years after the end of your relationship with Bodywise.

This 10-year period is Bodywise's current provisional retention policy and is subject to professional review. It is not presented as a statutory rule requiring all health information to be retained for ten years.

The archive is limited to material evidence reasonably necessary for safety, accountability or establishing, exercising or defending legal claims, such as:

PAR-Q or material safety-screening answers, relevant safety declarations, relevant safety flags, material consent evidence, important warnings or advice, recommendations to stop or change activity or seek appropriate professional help, evidence that material advice was declined or not followed, and the minimum context needed to understand that evidence.

The archive is not a copy of your Bodywise account.

It is not used for ordinary coaching, personalisation, analytics, marketing or advertising.

Accounting and transaction records

Necessary accounting and transaction records are retained for six years after the relevant accounting or tax period, or longer only where genuinely required by an unresolved tax enquiry, dispute or other applicable legal obligation.

That accounting period does not justify keeping unrelated training, health or nutrition records.

Administrator audit records

Relevant administrator audit records are normally retained for 12 months.

Privacy and data-rights request records

A minimal record of a completed privacy/data-rights request is normally retained for 24 months after the request is closed.

Email and message-delivery evidence

Minimal delivery evidence is normally retained for 24 months.

Marketing suppression

Minimal unsubscribe/objection information may be retained for as long as reasonably necessary to ensure the opt-out continues to be honoured.

Feedback and other operational records

Where no fixed period has yet been set, information is retained only for as long as reasonably necessary for the purpose for which it is held and is reviewed under Bodywise's retention schedule.

Account deletion

You can request account deletion through Bodywise.

Deletion removes or anonymises ordinary Bodywise account information and ordinary user files as applicable.

It does not necessarily erase the limited records described above where Bodywise has a lawful reason to retain them.

Retained legal/safety information is separated from ordinary product use.

Deleting your Bodywise account is not the same thing as cancelling an Apple App Store subscription.

If you subscribed through Apple, you must manage or cancel the subscription through your Apple Account.

If you subscribed through the Bodywise website, use the applicable website/Paddle cancellation route.

Some service providers may retain backup or transactional records under their own systems and legal obligations. Bodywise does not promise immediate deletion from a provider backup where that behaviour has not been verified.

Your rights

Depending on the law that applies to you, you may have rights to:

• obtain confirmation that your information is being processed;
• access and obtain a copy of it;
• correct inaccurate information;
• request deletion;
• restrict certain processing;
• object to certain processing;
• receive portable data where applicable;
• withdraw consent;
• object to direct marketing;
• complain about how your information is handled;
• challenge a refusal of a request where applicable.

Using your rights

You may exercise these rights through Bodywise's privacy controls or by contacting privacy@bodywise.io.

We may need reasonable information to confirm your identity before disclosing or changing account information.

For UK GDPR rights, the normal response period is one month, subject to lawful extensions where applicable.

Additional rights by location

If UK GDPR applies, you may complain to the UK Information Commissioner's Office.

If EU GDPR applies, you may complain to the relevant supervisory authority in the EEA.

If Canadian privacy law applies, you may also have rights under applicable federal or provincial privacy law and may complain to the relevant Canadian privacy authority.

If Australia's Privacy Act applies, you may request access or correction and may complain to the Office of the Australian Information Commissioner.

If New Zealand's Privacy Act applies, you may exercise the applicable access, correction and complaint rights under that Act.

If Japanese APPI, Korean PIPA, Brazilian LGPD, Indian DPDPA, Swiss FADP, South African POPIA or another local privacy law applies, Bodywise will apply the mandatory rights and safeguards required by that law.

Some jurisdictions require additional local-language, representative, transfer or regulatory steps that cannot be satisfied merely by this English-language notice.

Security

Bodywise uses access controls and technical/organisational measures intended to protect personal information from unauthorised access, disclosure, alteration or loss.

No internet service can guarantee absolute security.

If you believe you have found a security problem, contact security@bodywise.io.

Children

Bodywise is intended only for adults aged 18 and over.

We do not knowingly provide Bodywise accounts to children.

If you believe a person under 18 has created an account, contact privacy@bodywise.io.

Changes to this notice

We may update this notice when the service, law or data practices change.

Material changes will be communicated where appropriate.

A change to a Privacy Notice is not itself treated as consent.

If a new or materially expanded use of health information requires fresh consent, Bodywise will request that consent before relying on it.

Previous versions are retained in Bodywise's policy history.