Privacy Policy

1. Data controller

The data controller responsible for processing your personal data is:

• ALEX DEVELOPMENT (EI)
• Registered address: 8 Chemin de Landouezec, 22500 Paimpol, Britany, France.
• Trade register: N/A · SIRET 91850643700014
• Contact for privacy matters: [email protected]

We have not appointed a Data Protection Officer (DPO) because our processing does not meet the thresholds set out in Article 37 GDPR. If this changes we will publish the DPO’s contact details here.

2. Personal data we collect

We collect only the data we need to run the Service. We do not sell your data, we do not use it for advertising, and we do not profile you for third-party marketing.

2.1 Account & identity

• Email address (required to create an account and sign in)
• Authentication identifiers from Sign in with Apple or Sign in with Google when you choose those methods (an opaque user ID and, if you consent, your name and email — including Apple’s private-relay email)
• Display name and optional avatar URL
• Preferred unit (kilograms / pounds)
• Account creation timestamp and last sign-in timestamp

2.2 Fitness & training data

This is the core of what the Service does. It is stored on your device and on our backend so it syncs across devices.

• Custom training programs you build (name, structure, schedule)
• Workout sessions: start/end time, exercises performed, sets, repetitions, weight lifted, tempo, rest, free-text notes
• Body weight log entries you record
• Custom exercises you create (name, target muscle, equipment)

2.3 Subscription & purchase data

• Subscription status (free, trialing, active, in grace period, cancelled, expired)
• The product you purchased (plus_monthly_199 or plus_yearly_999), the store (App Store / Google Play), the billing period, the renewal date and the cancellation date if applicable
• A pseudonymous identifier issued by RevenueCat that lets us match your subscription events to your account

We do not see or store your card number, bank details or any payment credentials. All billing is handled by Apple or Google directly.

2.4 Health data (only if you opt in)

On iOS, the App can integrate with Apple Health (HealthKit). On Android, it can integrate with Health Connect. The only data types we touch are workouts (write only) and body weight (read only).

Workouts. When you finish a workout in the App, we write the session start time, end time, type (strength training) and an estimated calorie figure to your device’s Health store. This record stays on your device — we do not copy it back to our servers.

Body weight. When you turn on Health sync in Settings, we read your body-weight samples from your device’s Health store and upload them to your Powr account so they appear in your weight log alongside any manual entries. Each sample is tagged so you can tell which entries came from Health and which you typed in. Sync only runs while the App is open and only for the body-weight type — we never read heart rate, sleep, steps, workouts already saved, location or any other Health data type.

Health data is never used for advertising, never sold, never shared with third parties, and never used for any purpose other than delivering the fitness-tracking feature you enabled. You can disable Health sync from inside the App at any time, and you can revoke OS-level access in iOS Settings → Privacy & Security → Health, or Android Settings → Apps → Health Connect.

2.5 Technical & diagnostic data

• App version, operating system version, device model and language (sent with normal API requests)
• Server logs from our hosting providers, including the IP address of requests, kept for security and abuse prevention

2.6 Data we do NOT collect

• We do not currently use any analytics or tracking SDK in the App.
• The Site does not use cookies, pixels or analytics scripts.
• We do not collect precise location data.
• We do not access your contacts, photos or camera. Microphone access is only used on demand when you record a voice note (see 2.7).

2.7 Voice notes and AI-assistant data (Powr Plus features)

Some Powr Plus features rely on external artificial intelligence models. When you use those features, the data described below temporarily leaves our servers so the AI provider can produce a response:

• Voice notes for transcription. When you record a voice note inside the App, the audio file is sent to OpenAI’s Whisper API to be transcribed into text. The audio recording is not retained on our servers — only the resulting text is stored in your account.
• AI coach, plan generation and summaries. When you chat with the in-app coach, ask the App to generate or edit a training program, swap an exercise, or request a post-workout summary, we send Anthropic’s Claude API the data needed to produce a useful response. This includes the message you wrote, your prior coach conversation, summaries of recent workout sessions (exercise names, sets, repetitions, weight), your training goals and preferences, and your first name. We do not send your email address, payment information, body-weight history, or Apple Health / Health Connect data.

These features are only available while you have an active Powr Plus subscription and are subject to per-day usage limits. They are described in more detail in section 10 below.

3. How we collect personal data

• Directly from you, when you create an account, sign in, log a workout, record a body-weight entry, chat with the AI coach, record a voice note, or contact support.
• From the App stores (Apple App Store, Google Play) via RevenueCat, when you buy or renew a subscription.
• Automatically, when your device sends standard metadata (IP, OS, app version) with each API request.

4. Legal basis for processing (GDPR Article 6)

5. Purposes of processing

• Authenticating you and keeping your account secure.
• Storing and syncing your programs, sessions, sets and body weight across devices.
• Activating and managing your subscription, including the 7-day free trial.
• Generating AI-assisted training plans, coach replies, post-workout summaries and exercise-swap suggestions when you use the Powr Plus AI features.
• Transcribing voice notes you record inside the App into text when you use the voice-note feature.
• Delivering transactional emails such as one-time sign-in codes.
• Providing customer support when you contact us.
• Diagnosing crashes and improving stability (when reported manually by you, or via aggregated server logs).
• Complying with applicable law (tax records, responding to lawful requests).

6. Who we share data with

We share personal data only with the processors and partners listed below, and only to the extent strictly necessary. Each is bound by a Data Processing Agreement (DPA) and by appropriate technical and organisational safeguards.

We never sell your personal data, and we never share it with advertisers, data brokers, insurers, employers or credit-scoring agencies.

7. International transfers

Some of our processors are located outside the European Economic Area, in particular in the United States: Anthropic, OpenAI, Resend, RevenueCat, Apple and Google. When personal data is transferred to those processors, the transfer is protected by:

• the European Commission’s Standard Contractual Clauses (Decision 2021/914), incorporated into the data processing agreement we have signed with each provider;
• the EU–US Data Privacy Framework, where the receiving organisation is certified under it; and
• additional contractual and technical safeguards (encryption in transit, short retention windows, role-based access).

Specifically for the AI processors that handle Powr Plus features:

• Anthropic deletes API inputs and outputs after 7 days (extended only where required for trust & safety review of flagged content) and does not use customer data to train its models. See Anthropic’s data-use documentation.
• OpenAI deletes API inputs and outputs after 30 days and does not use API customer data to train its models. See the OpenAI Data Processing Addendum.

You can request a copy of the safeguards in place by emailing [email protected].

8. How long we keep your data

9. Your rights under the GDPR

You have the following rights, which you can exercise free of charge by emailing [email protected]. We respond within one month (extendable to three months for complex requests, in which case we will tell you within the first month).

• Right of access (Art. 15): obtain a copy of the personal data we hold about you.
• Right to rectification (Art. 16): have inaccurate or incomplete data corrected.
• Right to erasure (Art. 17): have your data deleted. You can also delete your account directly from the App; this triggers full deletion within 30 days, except for the records we are legally required to keep.
• Right to restrict processing (Art. 18).
• Right to data portability (Art. 20): receive your training and body-weight history in a structured, commonly used and machine-readable format.
• Right to object (Art. 21) to processing based on our legitimate interests, including server-log retention for security.
• Right not to be subject to automated decision-making (Art. 22): we do not make any decisions about you with legal or similarly significant effects using solely automated means. Some Powr Plus features generate informational suggestions (auto-progression load and rep proposals from a deterministic rule based on your own performance, and AI-generated training plans, coach replies and post-workout summaries from external AI models — see section 10). These are always advisory: you can ignore, edit, override or disable them at any time, and they do not affect your access to the Service.
• Right to withdraw consent at any time, where processing is based on consent (e.g. health-data integrations); the withdrawal does not affect the lawfulness of processing carried out before it.
• Right to lodge a complaint with the French data protection authority (CNIL — cnil.fr) or with the supervisory authority in your country of residence.

10. AI features and transparency

Some Powr Plus features are powered by artificial intelligence models operated by third parties. In line with Article 50 of the EU AI Act, we want to be transparent about how these features work and what their limits are.

10.1 You are interacting with an AI system

The AI coach, the AI training-plan generator and editor, the post-workout summaries and the exercise-swap suggestions use Anthropic’s Claude models (currently claude-sonnet-4-6 and claude-haiku-4-5). Voice-note transcription uses OpenAI’s Whisper (gpt-4o-transcribe). When you use these features, the recommendations, replies and transcripts you see are produced automatically by a large language model and are not reviewed by a human before being shown to you.

10.2 AI outputs can be wrong

Large language models can produce inaccurate, incomplete or outdated information. AI-generated training advice is for general informational purposes only and is not a substitute for the judgement of a qualified fitness, medical or healthcare professional. Always fact-check important information before acting on it. The health-and-fitness disclaimer in our Terms of Service also applies to AI-generated content.

10.3 What we send to AI providers, and what we do not

We minimise the data sent to AI providers. We send only what is needed to produce a useful response:

• To Anthropic: your free-text messages, prior coach conversation, summaries of recent workout sessions, your training goals and preferences, and your first name.
• To OpenAI: the audio file of the voice note you are transcribing.

We do not send your email address, payment information, body-weight history, Apple Health / Health Connect data, IP address or precise device identifiers to either provider.

10.4 No training on your data

Anthropic and OpenAI have contractually agreed not to use the data we send through their APIs to train, retrain or improve their models. Both providers delete API inputs and outputs within a short retention window used for abuse monitoring and debugging: 7 days for Anthropic and 30 days for OpenAI.

10.5 Sub-processors of our AI providers

Anthropic and OpenAI may engage sub-processors (typically cloud-infrastructure providers such as Amazon Web Services or Google Cloud) to deliver their services. Their current sub-processor lists are published at trust.anthropic.com and openai.com/policies/sub-processor-list.

10.6 Turning AI features off

AI features are only enabled while you have an active Powr Plus subscription. If you cancel your subscription, your data will no longer be sent to Anthropic or OpenAI. You can also ask us at any time to stop using AI features on your account, without cancelling your subscription, by emailing [email protected].

11. Security

We use encryption in transit (HTTPS / TLS 1.2+), encryption at rest on the database, scoped row-level security so each user can only access their own rows, secret keys stored outside source control, and regularly rotated credentials. No system is perfectly secure: if a breach is likely to result in a high risk to your rights and freedoms, we will notify you and the CNIL within 72 hours, as required by Art. 33–34 GDPR.

12. Children

The Service is not directed at children under 16. We do not knowingly collect personal data from children under 16. If you become aware that a child has provided us with personal data, please contact [email protected] and we will delete it.

13. Cookies and similar technologies

The Site (https://powr-app.com) does not set any cookies, does not embed third-party trackers, and does not run any analytics scripts. If we ever introduce non-essential cookies, we will publish an updated cookie policy and, where required, ask for your prior consent through a banner that complies with the CNIL’s recommendations.

The App stores your authentication session and a small cache of previously-loaded screens locally on your device, using the operating system’s standard storage facilities, so that you stay signed in and the screens you visited recently load instantly. These are not cookies, are not shared with any third party, and are removed when you sign out or uninstall the App.

14. Notice for California residents (CCPA / CPRA)

California residents have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

• Right to know what personal information we collect, use, and disclose.
• Right to delete personal information.
• Right to correct inaccurate personal information.
• Right to opt out of the sale or sharing of personal information.
• Right to limit the use of sensitive personal information.
• Right to non-discrimination for exercising these rights.
• Right to opt out of, and request meaningful information about, the use of automated decision-making technology (ADMT). The AI features described in section 10 are advisory and you can disable them at any time by cancelling your Powr Plus subscription or by writing to [email protected].

We do not sell or share personal information as those terms are defined under the CCPA, and we do not use sensitive personal information for any purpose other than providing the Service. You do not need to submit a “Do Not Sell or Share My Personal Information” request, but you can confirm or exercise your rights at [email protected].

Residents of other US states with comparable privacy laws (Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and others) may exercise the equivalent rights through the same channel.

15. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be communicated through an in-app notification or by email at least 30 days before they take effect. The “Last updated” date at the top of this page always reflects the current version. Previous versions are available on request.

16. Contact

For any privacy question or to exercise your rights, contact us at [email protected] or by post at:

ALEX DEVELOPMENT
8 Chemin de Landouezec, 22500 Paimpol, Britany, France.

This Privacy Policy is also available together with our Terms of Service and Legal Notice.