Privacy Policy
Effective date: April 12, 2026
This Privacy Policy explains what data we collect, how we use it, and your rights under the General Data Protection Regulation (GDPR) and other applicable data protection laws.
The short version: ProgressPilot is local-first. Your workout data stays on your device and your personal iCloud account. We don’t run analytics, don’t serve ads, and don’t track your behavior.
1. Controller
ProgressPilot is an independent app developed and operated from Finland (EU). The controller for personal data processed in connection with the app is the operator of ProgressPilot.
The primary point of contact for all privacy matters is:
Email: [email protected]
If you require a postal address or registered business identifier in connection with a formal data-protection request (for example, a complaint to a supervisory authority), please contact us at the email above and we will provide the relevant details for your request.
If you have questions about this Privacy Policy or want to exercise your privacy rights, contact us using the email above.
2. Legal Bases for Processing
We process personal data only where we have a valid legal basis under applicable data protection law. Depending on the feature you use, these legal bases may include:
| Processing Activity | Legal Basis |
|---|---|
| Account authentication | Performance of a contract |
| Subscription management | Performance of a contract; compliance with legal obligations for financial/accounting records where applicable |
| AI coaching requests | Performance of a contract |
| HealthKit reads and writes | Your explicit device-level permission / consent |
| Support communications | Legitimate interests in providing support and maintaining service quality; performance of a contract where the request relates to your use of the app |
| Local notifications | Generated on-device at your request through app settings; where personal data is processed by us for this feature, we rely on your consent/request |
3. Data We Collect
3.1 Account Data
When you sign in with Apple or Google, we use Firebase Authentication to create a unique account identifier (Auth UID). This UID is used to authenticate AI requests and manage your subscription. We do not store your name, email address, or profile photo in our own application database.
- What: Firebase Auth UID, authentication provider (Apple or Google)
- Where stored: Firebase Authentication (Google Cloud infrastructure)
- Retention: Until you delete your account
3.2 Workout Data
All training data you enter — sessions, exercises, sets, reps, weights, Performance Index scores, personal records, weekly programs, and your profile (goals, equipment, fitness level, injury notes) — is stored on your device using Apple’s SwiftData framework.
If iCloud is enabled on your device, this data syncs to your personal iCloud account via Apple CloudKit. This sync is between your own devices through your own Apple ID.
We do not store your workout history in our own application database. Limited account, subscription, and infrastructure data are processed by the service providers described below.
- What: Training sessions, sets, reps, weights, PI scores, personal records, weekly programs, user profile
- Where stored: On your device (SwiftData) + your iCloud account (CloudKit), if enabled
3.3 AI Coaching Requests
When you use AI features such as weekly program generation, daily targets, exercise swaps, progression advice, or coaching summaries, the app sends only the workout and profile fields needed to generate that specific coaching response.
Examples of fields that may be included, depending on the feature, are: exercise names, sets, reps, weights, Performance Index scores, weekly schedule, equipment access / gym tier, training goal, fitness level, session length, readiness/soreness feedback, and training constraints you choose to provide in the app profile (such as injury notes or avoided movements).
Special category data. Free-text you enter in fields like “injury notes” may qualify as health data (special category data) under the GDPR. You decide what to enter. If you choose to include such information in your profile, we rely on your explicit consent (by your act of entering and saving it) to include it in AI coaching requests so the coach can adapt your program to your situation. You can remove or change these entries at any time in the app.
We do not intentionally include your name, email address, photos, precise location, advertising identifiers, contacts, or HealthKit data in AI prompts.
- How: Sent via encrypted HTTPS to our Cloudflare Worker proxy, which forwards the request to the OpenAI API
- Retention: We do not store full AI prompt history in our own application database. Our service providers may retain limited request data for security, abuse prevention, and service integrity purposes under their own contractual terms and policies. OpenAI processes requests under their API Data Usage Policy; API inputs and outputs are not used by OpenAI to train its models by default.
No solely automated decisions with legal or similarly significant effects (GDPR Art. 22). AI-generated programs, targets, and coaching notes are suggestions for guidance only. You remain in full control of your training and can edit, skip, swap, or override any AI-generated exercise, weight, rep, or set at any time. The app does not use these outputs to make decisions that produce legal or similarly significant effects about you.
3.4 Subscription Data
Your subscription is managed through RevenueCat. We check your subscription status to determine whether you have access to premium features.
- What: Subscription status (active, expired, trial), subscription tier (monthly/annual), expiration date
- Where stored: RevenueCat servers, linked by your Firebase Auth UID (not your name or email)
3.5 Health Data (Apple HealthKit)
HealthKit access is entirely opt-in and requires your explicit permission through Apple’s permission controls.
- What we read: Body weight measurements and cardio workouts (running, cycling, swimming, walking, hiking, rowing, stair climbing)
- What we write: Completed strength training workouts with duration and estimated calories burned
- Where processed: HealthKit data is processed only on your device and is not transmitted to our servers or included in AI requests
- Revocation: You can revoke HealthKit permissions at any time in iOS Settings > Privacy & Security > Health
We do not use HealthKit data for advertising, marketing profiling, or data brokerage. We do not sell HealthKit data. We do not disclose HealthKit data to third parties except where required by law.
The Health app and the underlying HealthKit data store are operated by Apple on your device under Apple’s own platform and privacy terms. Your permissions and what Apple does with Health data sit outside the scope of this policy.
3.6 Push Notifications
If you enable notifications, the app schedules local notifications for workout reminders, streak alerts, and weekly digests. All notifications are generated on-device. We do not operate a server-side push notification system.
4. Data We Do NOT Collect
- No analytics (Firebase Analytics is explicitly disabled in our app configuration)
- No ad tracking or advertising identifiers
- No crash reporting or telemetry
- No location data
- No third-party SDKs that collect behavioral data
- No App Tracking Transparency prompt (because we do not track)
5. Third-Party Services
We use the following third-party services in clearly defined roles:
| Provider | Purpose | Role |
|---|---|---|
| Firebase Authentication (Google) | Sign-in and account authentication | Service provider (processor) |
| OpenAI | AI coaching request processing | Service provider (processor) |
| RevenueCat | Subscription entitlement management | Service provider (processor) |
| Cloudflare | Website hosting and proxy infrastructure | Service provider (processor) |
| Apple CloudKit / iCloud | User-controlled sync between user’s devices | Apple acts under its own platform terms |
6. International Data Transfers
ProgressPilot is operated from Finland (EU). Some service providers we use may process personal data outside the European Economic Area, including in the United States.
Where required, we rely on appropriate safeguards under applicable data protection law, such as the European Commission’s Standard Contractual Clauses (SCCs) and/or other lawful transfer mechanisms made available under our data-processing agreements with those providers.
- Firebase Authentication (Google) — authentication data may be processed in the United States or other regions Google operates in.
- OpenAI — AI request content may be processed in the United States.
- RevenueCat — subscription status data may be processed in the United States.
- Your workout data remains on your device and in your personal iCloud account (Apple infrastructure), subject to Apple’s own platform and privacy terms.
You may contact us if you would like more information about the safeguards relevant to a specific transfer.
7. Your Rights (GDPR)
As a user in the European Economic Area, you have the following rights:
- Right of access: Request a copy of the data we hold about you
- Right to rectification: Correct any inaccurate personal data
- Right to erasure: Delete your account and all associated data
- Right to data portability: Request a copy of personal data you provided to us in a structured, commonly used, machine-readable format. All users — free or premium — can exercise this right by contacting [email protected]. Premium subscribers can also use the in-app CSV export (Settings > Export Data) as a self-serve convenience; this is an additional product feature and is not a condition of your portability right.
- Right to restriction of processing: Request that we limit how we use your data
- Right to object: Object to the processing of your data
- Right to withdraw consent: Revoke HealthKit access or notification permissions at any time via iOS Settings
Exercising Your Rights
To exercise any of these rights, contact us at [email protected].
We may need to verify your identity before completing a request. We aim to respond within one month, subject to extensions permitted by applicable law. In some cases, we may need to retain limited information where required for legal, accounting, fraud-prevention, or security reasons.
You can initiate account deletion directly in the app under Settings > Delete Account. Contacting support is optional if you need additional help or believe some associated data still remains.
You also have the right to lodge a complaint with the Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto), Finland’s supervisory authority: tietosuoja.fi.
8. Data Retention
- Workout data: Stored on your device indefinitely until you delete it or delete your account
- Firebase Auth: Retained until you request account deletion
- RevenueCat: Subscription history retained per RevenueCat’s policy for accounting and legal purposes
- AI requests: Not retained by our proxy. Subject to third-party provider retention policies for security and abuse monitoring
9. Website Data, Cookies & Local Storage
Our website does not use advertising cookies or third-party analytics tools for behavioral tracking.
Like most websites, our hosting and infrastructure providers may process limited technical information such as IP addresses, request metadata, and security logs to deliver the website, prevent abuse, and maintain service reliability. We do not use this information to build advertising profiles.
We do not use analytics or advertising cookies on this website. Our hosting or infrastructure providers may set strictly necessary technical cookies in limited cases (for example, to deliver a secure connection).
Cookies and local storage (ePrivacy). We do not use tracking cookies on this website. Any browser cookies or local-storage entries we use are strictly necessary for the site to work (for example, remembering that you expanded a section). No consent banner is shown because no non-essential cookies are set.
If you contact us by email, we process the information you provide to respond to your request.
10. Children’s Privacy
ProgressPilot is not directed at children under 16 years of age. We do not knowingly collect personal data from children. If you believe a child has provided data to us, please contact us and we will delete it promptly.
11. Changes to This Policy
We may update this Privacy Policy from time to time. If we make material changes, we will notify you via an in-app notice and update the effective date at the top of this page.
12. Contact
For privacy inquiries or to exercise your GDPR rights:
Email: [email protected]