Privacy Policy

Last Updated: December 18, 2025

1. Introduction

1.1 Who We Are

FitPilot ("we," "us," or "our") is operated by FitPilot Software (Individual), ABN 71 676 487 239, a business registered in Queensland, Australia.

Contact Details:

Email: privacy@fitpilot.me
Address: 7 Clunies Ross Court, Suite #1035, Eight Mile Plains, QLD 4113, Australia
Phone: +61 499 628 369

1.2 Our Commitment to Privacy

We are committed to protecting your privacy and handling your personal and health information responsibly and in accordance with:

Privacy Act 1988 (Australia) and the Australian Privacy Principles (APPs)
Privacy Act 2020 (New Zealand) and the Information Privacy Principles (IPPs)
Other applicable privacy and health information laws, as relevant to the facts and your role

1.3 Scope of Policy

This Privacy Policy explains:

What information we collect
How we collect it
Why we collect it
How we use, store, and protect it
Who we share it with
Your rights and choices

This policy applies to:

FitPilot website (fitpilot.me)
FitPilot mobile applications (iOS and Android)
All related services and features

2. Information We Collect

2.1 Account and Profile Information

Full name
Email address
Phone number
Date of birth
Gender
Profile picture (optional)
Account credentials (password - stored as a secure one-way hash)

2.2 Sensitive Health Information ⚠️ EXTRA PROTECTIONS APPLY

We collect sensitive health information to ensure safe exercise participation and effective training:

Medical Screening (ESSA Pre-Exercise Questionnaire):

Heart conditions or stroke history
Chest pain during rest or activity
Dizziness or fainting during exercise
Asthma requiring emergency attention
Diabetes and blood sugar control
Other conditions requiring special consideration
Recent hospitalizations
Pregnancy status

Biometric Measurements:

Weight, height, waist circumference
Body fat percentage
Blood pressure readings
Cholesterol levels (total, HDL, LDL, triglycerides)
Fasting blood glucose
Current medications

Family Medical History:

Heart disease in family members
Ages of cardiac events
Hereditary conditions

Lifestyle Factors:

Smoking status
Physical activity levels
Exercise history

Injury Information:

Previous injuries
Current injuries and pain
Movement limitations
Musculoskeletal conditions

Dietary Information:

Food allergies
Dietary restrictions
Medical dietary requirements
Food preferences

Progress Data:

Body measurements over time
Progress photos
Fitness assessments
Workout performance
Meal logs
Daily wellness check-ins

Emergency Contact:

Name, phone, relationship

2.3 Fitness and Training Data

Workout plans and logs
Exercise performance
Meal plans and nutrition logs
Progress measurements
Goals and preferences
Trainer notes

2.3.1 Apple Health / HealthKit (Optional)

If you choose to connect Apple Health/HealthKit (via our iOS app), we may collect and store sensitive health and biometric data including heart rate metrics (resting, active, average), heart rate variability, VO2 max, step counts, activity energy burned, exercise minutes, sleep analysis, and other health metrics you authorize. This data is treated with enhanced protections under health privacy laws (HIPC in NZ, APP 5 in AU).

What we collect: Activity summaries, heart rate data, sleep metrics, and exercise tracking data you explicitly authorize.

Why we collect it: To provide personalized fitness insights and progress tracking when you opt-in.

How to disconnect: You can revoke access at any time through iOS Settings > Privacy & Security > Health > FitPilot, or by contacting us to delete your account.

2.4 Communication Data

Messages between trainers and clients
Support tickets
Feedback and surveys
Email correspondence

2.5 Payment Information

Billing address
Payment method (tokenized by Stripe)
Purchase history
Subscription status

2.6 Technical Data

IP address and location (city/country)
Device type and operating system
Browser type and version
App version
Usage patterns
Session data
Error logs

2.7 Cookies

See our Cookie Policy at /cookies for details, and manage your preferences any time at /cookie-settings.

3. How We Collect Information

3.1 Directly From You

Account registration
Pre-exercise screening forms
Fitness assessments
Workout and meal logging
Progress photos
Messages
Support requests

3.2 Automatically

Usage analytics
Device information
Log files
Cookies and tracking

3.3 From Third Parties

OAuth providers (Google, Apple)
Payment processors (Stripe)
Analytics (optional, with consent)

4. How We Use Your Information

4.1 Service Provision

Create and manage accounts
Facilitate trainer-client relationships
Provide workout and meal planning
Track fitness progress
Enable secure messaging
Process payments
Customer support

4.2 Safety and Risk Management

Screen for exercise risks
Identify medical clearance needs
Monitor for adverse responses
Assess program appropriateness
Emergency response

4.3 AI Features (With Consent)

Generate workout programs
Create meal plans
Provide recommendations
Analyze progress

4.4 Communication

Service notifications
Account updates
Billing reminders
Customer support
Marketing (only with consent)

4.5 Service Improvement

Analyze usage patterns
Identify bugs
Test new features
Research (anonymized)
Enhance user experience

4.6 Security and Compliance

Detect unauthorized access
Prevent fraud
Investigate incidents
Legal compliance
Protect rights

4.7 What We DON'T Do

Market with health data (without consent)
Research with health data (without consent)
Share with third-party marketers
Sell personal information
Share with insurance/employers

5. Who We Share Information With

5.1 Your Personal Trainer

Can access:

All health screening information
Medical history
Workout and meal logs
Progress photos and measurements
Messages with them
Goals and notes

Must:

Keep information confidential
Use only for training
Comply with privacy laws
Report breaches immediately

5.2 AI Services (If You Use AI)

OpenAI (USA):

Processes selected information for workout/meal generation
Only receives trainer-selected information
Subject to OpenAI privacy policy
OpenAI’s handling of inputs/outputs is governed by OpenAI’s API terms and policies, and may change over time

Sent to AI:

Goals and experience
Activity levels
Dietary preferences
Trainer-selected limitations

NOT sent:

Complete medical history
Blood test results
Emergency contacts
Progress photos

5.3 Service Providers

Hosting:

Vercel (Global): Platform, database, file storage
Security and encryption features where supported by the provider and configuration (we do not claim specific certifications here unless we have current, in-scope evidence)

Payments:

Stripe (USA): Credit card processing and trainer payouts
PCI-DSS compliant
We never store card details
When trainers receive payments through our platform, we create Stripe Connected Accounts on their behalf. Stripe collects account verification information (such as bank account details, tax ID, and business information) directly from trainers according to Stripe's privacy policy and regulatory requirements.

Email:

Resend/Postmark (USA): Transactional emails
Name, email, minimal content

Analytics (Optional):

Usage patterns only
Anonymized data
No health information

Push Notifications:

Apple/Google (USA): App notifications
Device token, minimal content

Marketing/Measurement (Optional, With Consent):

Meta (Facebook Pixel): If enabled and if you consent to marketing cookies, Meta may receive pageview/event data and associated device/browser identifiers for marketing measurement.

5.4 Legal Requirements

We may disclose personal information when required by law, including:

Court orders, subpoenas, or warrants
Government investigations or requests from law enforcement
Regulatory requirements under Australian or New Zealand law

Government/Law Enforcement Requests: If we receive a request from government authorities, we will notify affected users where legally permitted and cooperate with lawful requests. We maintain records of such disclosures and may publish transparency reports about government data requests (excluding national security matters).

5.5 Business Transfers

Mergers or acquisitions
Privacy protections continue
You'll be notified
Can delete before transfer

5.6 With Your Consent

When you explicitly authorize

5.7 We NEVER

Sell personal information
Sell health information
Share with marketers (without consent)
Share with insurance companies
Share with employers
Research with health data (without consent)

5.8 Google Calendar Integration (Optional)

What is synced: When you enable the integration, we temporarily fetch read-only Google Calendar event details (title, start/end time, all-day flag, description, and location) to display them beside your FitPilot schedule. Events are rendered on demand and not stored permanently on our servers.
Tokens & security: OAuth tokens are encrypted at rest, scoped to https://www.googleapis.com/auth/calendar.readonly, and can be revoked at any time from PT or Client Settings. Disconnecting immediately removes our ability to fetch your Google events.
No additional sharing: Google does not receive any extra FitPilot data through this integration. The overlay is one-way and exists purely for your convenience in spotting scheduling conflicts.

5.5 Data Storage and Processing Location

Where your data is processed: FitPilot uses cloud service providers (including hosting, storage, email, analytics/marketing, and AI providers) that may process data in Australia, New Zealand, and other countries where those providers operate. See /subprocessors for a summary of key providers.

International data transfers: Your personal information may be transferred to and processed in countries outside Australia and New Zealand depending on the providers and features you use (for example: Stripe for payments, email delivery, optional AI processing, push notification delivery, and optional marketing measurement). We take reasonable steps to ensure overseas recipients handle information appropriately.

Security measures (high level): We use a combination of safeguards such as access controls, audit logging, encryption for certain sensitive payloads, rate limiting, malware scanning for uploads, and incident monitoring. However, no method of transmission over the internet or electronic storage is 100% secure.

Data retention: We retain personal information for as long as needed to provide the Service, meet legal/compliance obligations, resolve disputes, and enforce our agreements. When you request account deletion, we may retain certain records (including health-related records) for a period (commonly up to 7 years) where required or reasonably necessary for compliance, audit, and dispute-resolution purposes.

6. International Data Transfers

6.1 Storage Locations

Vercel: USA, Europe, Asia-Pacific
OpenAI: USA (if using AI)
Stripe: USA
Email: USA

6.2 Cross-Border Transfers

Your information may be transferred to:

United States
Other countries where providers operate

Safeguards:

Contractual safeguards (such as data processing agreements) where appropriate
Other safeguards depending on the provider and feature (we do not represent that SCCs apply in all cases)
Encryption (transit and rest)
Access controls
Security audits
Compliance verification

6.3 APP 8 Compliance (Australia)

We ensure overseas recipients handle information according to APPs through:

Reputable providers
Data processing agreements
Encryption and security
Monitoring
This disclosure

By using FitPilot, you consent to international transfers.

6.4 IPP 12 Compliance (New Zealand)

We ensure overseas recipients provide comparable protections through:

Contractual safeguards
Security measures
You consent by using FitPilot

7. Security Measures

7.1 Technical Security

Encryption:

Encryption in transit (TLS/HTTPS, managed by our hosting providers)
Encryption at rest where supported by our storage providers and for certain sensitive payloads
Encrypted backups

Authentication:

Password hashing (bcrypt)
Role-based access
Session management
Multi-factor authentication (available for supported accounts/flows)

Infrastructure:

Secure cloud hosting (Vercel)
Regular security updates
Firewalls and DDoS protection
Secure APIs with rate limiting

Monitoring:

Audit logging
Anomaly detection
Failed login monitoring
Suspicious activity alerts

File Security:

Virus scanning
File type validation
Size limits
Secure storage (encrypted)

7.2 Organizational Security

Access Controls:

Limited staff access
Need-to-know basis
Confidentiality agreements

Training:

Staff privacy training
Trainer education
Regular updates

Policies:

Security policy
Incident response
Breach response plan
Regular audits

7.3 Third-Party Security

All providers must:

Sign data processing agreements
Implement security measures
Comply with privacy laws
Report incidents
Undergo audits

7.4 Your Responsibilities

Strong, unique passwords
Don't share credentials
Log out on shared devices
Enable MFA
Report suspicious activity
Keep devices updated

8. Data Retention

8.1 Active Accounts

While your account is active

8.2 Health Records (7 Years) ⚠️ LEGAL REQUIREMENT

Commonly retained for up to 7 years where required or reasonably necessary:

Pre-exercise screenings
Medical history
Medications
Injury records
Measurements
Progress photos (health-related)
Emergency contacts

Why: Australian and New Zealand law requires health record retention for liability protection

Even if you delete:

Health records archived securely
Not accessible for normal use
Only accessed if legally required
Destroyed after 7 years

8.3 Other Data

Data Type	Retention
Account info	30 days after deletion
Workout/meal logs	30 days after deletion
Messages	30 days after deletion
Payment records	7 years (tax law)
Support tickets	3 years
Analytics	2 years (anonymized after 6 months)
Security logs	1 year
Marketing consent	Until withdrawn

8.4 Destruction

Permanent secure deletion
Irreversible
Industry-standard methods
Verified and documented

9. Your Privacy Rights

9.1 Australian Rights (APPs)

Access: Copy of your information (30 days, free first request)

Correction: Fix inaccurate information (30 days)

Anonymity: Where practicable (not for trainer-client relationships)

Complaints: privacy@fitpilot.me → OAIC if unsatisfied

9.2 New Zealand Rights (IPPs)

Access: Copy of your information (20 working days)

Correction: Fix inaccurate information

Complaints: privacy@fitpilot.me → Privacy Commissioner if unsatisfied

9.3 All Users

Data Portability: Download in CSV/JSON

Deletion: Request account deletion (some health-related records may be archived for a period, commonly up to 7 years, for compliance/audit/dispute purposes)

Restrict AI: Opt-out of AI features

Withdraw Consent:

Marketing (immediate)
AI processing (immediate)
Essential processing may limit service

Object: Object to marketing or automated decisions

9.4 How to Exercise Rights

Email: privacy@fitpilot.me

Include:

Name and email
Specific right
Request details
Proof of identity

Response:

Simple: 14 days
Complex: 30 days (AU) / 20 days (NZ)
ID verification may be required

Fees:

First access: Free
Subsequent/complex: Reasonable fee

9.5 Communication Preferences

Marketing: Unsubscribe link or account settings (5 days)

Service Emails: Cannot opt-out (essential)

Push Notifications: Device or app settings

9.6 International Users and Your Privacy Rights

Australian Users: Users in Australia have privacy rights under the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), including the right to access, correct, and request deletion of your personal information. You may also lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

New Zealand Users: Users in New Zealand have privacy rights under the New Zealand Privacy Act 2020 and the Information Privacy Principles (IPPs), including the right to access, correct, and request deletion of your personal information. You may also lodge a complaint with the Privacy Commissioner.

Users in Other Jurisdictions: If you are located outside Australia or New Zealand, you may have rights under local data protection laws (including GDPR, CCPA, and other frameworks). We make no representations about our compliance with privacy laws outside Australia and New Zealand. You are responsible for determining whether our practices align with your local legal requirements. We recommend reviewing this Privacy Policy carefully and contacting us at privacy@fitpilot.me if you have concerns.

Exercising Your Rights: To exercise any of your privacy rights, regardless of your location, please contact us at privacy@fitpilot.me with your name, email address, and specific request. We will respond to your request in accordance with applicable law in your jurisdiction, typically within 14-30 days.

9.7 Data Export Rights

Your Right to Export: You have the right to request a copy of your personal data in a structured, commonly used, and machine-readable format. You can export your data at any time through your account settings under the "Privacy" section.

Available Export Formats:

JSON (Complete data structure with all relationships)
CSV (Tabular format for spreadsheets)

Data Categories Available for Export:

Personal & Profile Data (name, contact info, measurements, photos)
Health & Medical Data (screening results, conditions, supplements)
Activity & Workout Data (programs, meal plans, check-ins)
Communications (notifications, messages)
Audit Logs (optional, includes account activity history)

Export Attestation Requirement: Before exporting your data, you must agree to:

Store exported data securely in accordance with Australian Privacy Principles (APP 11) and NZ Privacy Act 2020 (IPP 5)
Delete exported data when no longer required for the lawful purpose
Not share exported data with unauthorized third parties
Report any breach involving exported data to FitPilot within 24 hours
Accept full responsibility for the security of exported data outside FitPilot's systems

Export Limitations: To prevent abuse and protect system performance, exports are limited to 3 requests per hour per user. For bulk or automated export requests, please contact privacy@fitpilot.me.

Security Notice: Once data is exported from FitPilot, our security controls no longer protect it. You become solely responsible for its security and proper handling.

10. Data Breaches

10.1 Our Obligations

Australia (NDB Scheme):

Assess within 24 hours
Notify OAIC if serious harm likely
Notify affected users ASAP
Provide: what data, when, actions, support

New Zealand:

Assess within 24 hours
Notify the Privacy Commissioner as soon as practicable when notification is required (we may use internal target timelines for operational response)
Notify affected users ASAP
Same information

10.2 Serious Harm

For health information, serious harm presumed:

Identity theft
Financial loss
Discrimination
Reputation damage
Physical/psychological harm
Employment impact
Insurance impact

All health breaches treated as potentially serious

10.3 Response Process

Within 24 hours:

Contain breach
Assess affected data
Determine harm likelihood
Begin investigation

As soon as practicable (AU/NZ):

Notify regulators
Notify affected users
Post website notice (large breach)

Support:

Protection guidance
Credit monitoring (financial data)
Counseling (health data)
Dedicated contact
Updates

Remediation:

Fix vulnerabilities
Enhance security
Review policies
Post-incident review
Report findings

10.4 Reporting Breaches (Trainers)

Must report within 24 hours:

Unauthorized access
Lost devices
Accidental disclosure
Suspicious activity

Report to: security@fitpilot.me

11. Health Information Special Protections

11.1 Legal Framework

Australia:

Privacy Act 1988 (APPs 3, 6, 11)
State/territory health information laws where applicable (depending on the facts)

New Zealand:

Health Information Privacy Code 2020
Privacy Act 2020

11.2 Extra Protections

Higher Standard:

Maximum security
Stricter access
Explicit consent
Longer retention (7 years)
Enhanced breach notification

Consent Requirements:

Explicit and informed
Reasonable purpose
Explain each piece
No secondary use without consent

Limited Use:

Fitness training only
Not for marketing (without consent)
Not for research (without consent)
Not shared (except as disclosed)

11.3 Enhanced Rights

Right to Know:

Why collected
How used
Who sees it
How protected
How long retained

Access Health Records:

Complete copy
Common format (PDF, CSV)
All screenings, notes, assessments

Correct Health Records:

Prompt correction (30 days)
Note attached if disputed

Complain:

privacy@fitpilot.me
OAIC / Privacy Commissioner
State health complaints

11.4 Pre-Exercise Screening

Mandatory: All clients before exercise

Consent Required:

Collection
Trainer sharing
7-year storage
AI processing (if used)
Overseas transfer

Accuracy Critical:

False info endangers safety
May cause injury/death
Voids protections
Account termination

11.5 Emergency Use

In medical emergencies:

Emergency contact accessible
Health info shared with responders
Permitted to protect life
You'll be notified after

11.6 Trainer Access

Can access:

Full screening
Medical history
Medications
Injuries
All measurements
Emergency contact

Must:

Keep confidential
Use only for training
Secure properly
Not share
Not remove from FitPilot

Must NOT:

Share with others
Use for research
Use for marketing
Disclose to employers/insurance

Penalties:

Account termination
Legal liability
Certification body reporting
OAIC/Commissioner reporting
Criminal penalties

12. AI Processing

12.1 OpenAI Processing

When using AI:

Selected info sent to OpenAI (USA)
Processes for workout/meal generation
May use aggregated data
OpenAI policy applies

May be sent:

Goals and experience
Activity levels
Dietary preferences
Trainer-selected limitations

NOT sent:

Full medical history
Medications
Blood tests
Family history
Emergency contacts
Photos
Complete screenings

12.2 Control

You can:

Opt-out entirely
Request manual creation
Withdraw consent
No penalty

Trainers can:

Choose what to send
Create manually
Control detail level

12.3 Data Minimization

Only minimum necessary information sent

12.4 Limitations

Not medical advice
May contain errors
Trainer reviews all content
Cannot replace professional knowledge

13. Children's Privacy

13.1 Age Requirement

Not for under 18

We don't knowingly:

Collect from under 18
Collect health info from under 18
Allow under 18 accounts

13.2 If Discovered

Delete within 48 hours
Terminate account
Notify account holder
Prevent future

13.3 Parents

If your child created an account:

Email privacy@fitpilot.me immediately
Provide: name, email, date
We'll delete within 48 hours

13.4 Trainers with Minors

If training under 18 in person:

Do NOT use FitPilot
Use paper forms
Get parental consent
Keep records outside FitPilot
Only register 18+ in FitPilot

14. Cookies

See our Cookie Policy for:

Types of cookies
Third-party cookies
Managing preferences
Opt-out options

Summary:

Essential: Always (required)
Analytics: Optional (consent)
Marketing: Optional (consent)
Control via consent banner

15. Policy Updates

15.1 Changes

We may update for:

Law changes
New features
Practice changes
User feedback

15.2 Notification

Material changes:

30 days email notice
In-app notification
Website notice
Date updated

Non-material:

Posted on website
Date updated
Continued use = acceptance

15.3 Material Includes

New information types
New purposes
New third parties
Security changes
Retention changes
Rights changes

15.4 Review

Review periodically
Check date
Contact with questions
Update preferences

16. Regional Provisions

16.1 Australia

Australia (state/territory health information laws):
Depending on the facts (including where you live and the type of service provided), additional state/territory health information laws may apply. We do not rely on a single “Queensland Health Records Act” reference for all cases.

State Complaints:

QLD: Health Ombudsman
Other states: respective offices

16.2 New Zealand

Health Information Privacy Code:

Special health rules
Enhanced protections
Specific requirements

Privacy Commissioner:

16.3 EU (If Applicable)

GDPR Rights:

Restriction of processing
Object
Automated decision opt-out
Supervisory authority complaints

EU Representative:
[If EU users, appoint representative]

16.4 California (If Applicable)

CCPA/CPRA Rights:

Right to know
Right to delete
Right to opt-out (we don't sell)
Right to non-discrimination

17. Contact and Complaints

17.1 Privacy Questions

Email: privacy@fitpilot.me
Mail: Privacy Officer, FitPilot Software (Individual), 7 Clunies Ross Court, Suite #1035, Eight Mile Plains, QLD 4113, Australia
Phone: +61 499 628 369

17.2 Complaints

Step 1: Contact Us

Email: privacy@fitpilot.me
Include: name, contact, concern, resolution
Acknowledge: 5 days
Respond: 30 days (AU) / 20 days (NZ)

Step 2: External

Australia:

OAIC: www.oaic.gov.au, 1300 363 992

New Zealand:

Privacy Commissioner: www.privacy.org.nz, 0800 803 909

17.3 Health Complaints (Australia)

Queensland:

Health Ombudsman: www.oho.qld.gov.au, 133 646

Other states:

Local health complaints commission

17.4 Other Contacts

Legal: legal@fitpilot.me
Security: security@fitpilot.me
Data Access: privacy@fitpilot.me
Support: support@fitpilot.me

By using FitPilot, you acknowledge that you have read, understood, and agree to this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein.

Version: December 18, 2025
Effective Date: December 18, 2025

This version replaces all previous versions.