Privacy Policy

This Privacy Policy explains what personal information Coach collects, why we collect it, the categories of recipient we share it with, how long we keep it, and your rights. It applies to the Coach mobile application and to coach-app.ai.

It does not apply to personal information we process about employees, contractors or job applicants, and it does not govern services operated independently by others — including Apple, Google, the App Store and Apple Health — which provide their own privacy information.

Coach is provided by GreyMatter Labs LDN LTD, a company registered in England and Wales (number 17306415) with its registered office at 128 City Road, London EC1V 2NX, United Kingdom. In this policy, "we" and "Coach" mean that company, and "you" means the person using the app. We are the controller of the personal information described below.

If you are resident in Washington, Nevada or Connecticut, please also read our Consumer Health Data Privacy Policy, which provides the additional disclosures required under the consumer health-data laws of those states.

If anything in this policy is unclear, contact privacy@coach-app.ai.

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1. Summary

Coach is an AI training coach. Your training plan, the in-app coaching and chat, and your progress reviews are generated using large language models operated by a contracted artificial intelligence provider acting on our behalf.

• To provide the coaching, relevant information — including your profile, your reported injuries and your training — is sent to that provider. Section 4.
• Coach collects information about your body and your training, including data that is health information. Sections 2 and 5.
• Coach keeps a memory of short notes about you to personalise your coaching. You can view, export and delete these notes in the app. Section 3.
• Apple Health integration is optional and read-only. Section 5.
• We keep your information for as long as you hold an account, and delete it when you delete your account, subject to the limited exceptions in Section 11.
• You can export your data and delete your account from within the app. Section 12.

2. Information we collect, and why

We collect the following, and use it to provide and improve the Coach service.

Some of this information — in particular your reported injuries, the health-related notes in Coach's memory, and body measurements such as bodyweight and body-fat percentage — is health information and therefore special category personal information under UK data protection law. We handle it on the basis described in Section 5.

A note on what you type. Text you enter into Coach — in chat, in an injury note, or in feedback — is used and processed as written. Please avoid including information that is not needed for your coaching or your request.

The pre-exercise screening. During onboarding, Coach asks you to complete a short physical-activity readiness screening. We retain only the outcome — that the screening was completed and that you are proceeding. Completing it is not medical clearance, and Coach does not treat it as such (see the Terms of Use).

3. Coach's memory

To personalise your coaching, Coach keeps a memory of short notes about you — for example, a training preference, a goal, or a constraint you have described. Some notes record things you have told Coach; some are observations or inferences generated by an AI model from your conversations, which may be uncertain or inaccurate and are recorded as such. Some notes may concern your health or personal circumstances.

You can review and export (see Section 12) these notes in the app under Profile → Your data → What Coach remembers. You can delete any note, and you can add your own note to correct something. Deleted notes are removed and are not used by Coach again.

4. Artificial intelligence

Coach's conversational coaching and certain written content are generated using large language models operated by a contracted AI provider. That provider acts as our processor: it may use the information we send only on our documented instructions and to provide the contracted service, and not for its own purposes.

To generate your plan, coaching, progress commentary and reviews, relevant information is sent to that provider — this may include your profile, your reported injuries and their notes, your training, the contents of your conversations, the notes in Coach's memory, and body measurements (including any read from Apple Health). Requests do not include your account identifier or email address, though your name may appear where it forms part of the coaching context.

Under our current arrangements with that provider, the content we submit is not used to train the provider's models, and may be retained by the provider for a limited period (currently up to 30 days) for abuse monitoring before deletion, unless longer retention is legally required. A consequence is that a copy of submitted content may exist on the provider's systems for a period after it is sent, and is deleted on the provider's schedule rather than when you delete your Coach account. If we change AI provider, or the terms on which it processes your data, we will update this policy before doing so.

5. Health information and Apple Health

Lawful basis. Where we process health information, we rely on your explicit consent for the purposes of Article 9 of the UK GDPR, together with the basis of performance of our contract with you under Article 6. During onboarding we ask for your consent in separate, unticked choices:

• agreement to the Terms of Use and acknowledgement of this Privacy Policy;
• explicit consent to collect and use your health information; and
• explicit consent to disclose that health information to the providers that operate Coach, including the AI provider.

We record which version of the wording you agreed to and the date you agreed. Consent is not inferred from silence, pre-ticked boxes or continued use.

Because Coach cannot generate or adapt a training plan without health information, these consents are necessary to hold an account. You may withdraw them at any time by deleting your account or contacting privacy@coach-app.ai; withdrawal does not affect processing carried out beforehand. If you withdraw the consents required to provide Coach, we will be unable to continue providing the service and will close your account.

Certain information — an email address, and the core body and training information Coach needs to build a plan — is required to provide the service. Other information, such as your body-fat percentage, dietary preference, profile photograph and anything you choose to tell Coach, is optional.

Apple Health. Apple Health integration is optional and is activated only if you choose to connect it. Coach requests read-only access to your bodyweight and body-fat percentage; iOS shows you that scope and asks for your permission, which you can withdraw at any time in the Health app. A measurement read from Apple Health is treated in the same way as one you enter yourself: it is used solely to provide the service to you, including your progress charts and, where relevant, your coaching.

Coach does not sell Apple Health information, disclose it to data brokers, use it for advertising or marketing, or use it to build a behavioural advertising profile. On first connection Coach may import up to two years of available measurements. Disconnecting Apple Health stops further synchronisation but does not delete measurements already imported; to remove those, delete your account or contact privacy@coach-app.ai.

6. Permissions

Coach asks for the following device permissions at the point they are needed, and the app remains usable if you decline them:

• Notifications — for rest-timer alerts and training-day reminders, scheduled on your device. Managed in Profile → Notifications and in your iOS settings.
• Camera and photo library — only if you choose to set a profile photograph.
• Apple Health — only if you choose to connect it (Section 5).

7. How we use your information

We use personal information to create and operate your account; to generate and adapt your training plan and coaching; to provide your progress tracking and reviews; to provide customer support and respond to feedback; to secure the service and prevent misuse; and to comply with our legal obligations.

Our lawful bases under UK data protection law are: performance of a contract with you (for your account, subscription, plan, coaching and the disclosures needed to provide them); your consent (for health information, as described in Section 5, and for any future marketing, which we would ask for separately); our legitimate interests in operating, securing and improving the service and in handling feedback and complaints (we balance these against your interests); and compliance with legal obligations. Where we rely on legitimate interests, you may object as described in Section 12.

8. Automated decision-making

Coach uses software to generate training plans, recommend exercises, calculate progression and produce coaching. These processes do not produce legal effects concerning you or similarly significant effects, and so fall outside Article 22 of the UK GDPR. You can alter anything Coach proposes, decline any suggested change, and reduce any prescribed load, and you should apply your own judgement to what Coach recommends. The Terms of Use address what this means for your safety.

9. Who we share information with

We share personal information with the following categories of recipient. Where a recipient acts as our processor, it processes personal information on our documented instructions and under a written data-protection agreement. A processor may use the information only to provide the contracted services and for related purposes permitted by that agreement and applicable law, including maintaining the security and integrity of its service.

• an authentication and account-management provider;
• a subscription-management provider;
• an artificial intelligence provider (Section 4);
• a cloud hosting and database provider;
• a content-delivery provider (for coach-app.ai); and
• a workplace messaging provider, through which our team receives in-app feedback. If you include health information in feedback, it will appear in that copy; the collection and disclosure consents in Section 5 cover this, and you can avoid it by leaving such details out.

We will identify the specific companies, and how to contact them, on request to privacy@coach-app.ai.

Apple and Google are not our processors. Apple distributes Coach and processes payments; your payment-card details are held by Apple and not disclosed to us. Where you use Sign in with Apple or Google, that provider supplies an email address and, optionally, your name, under its own privacy notice.

Legal and regulatory disclosures. We may disclose personal information where required by a valid legal or regulatory requirement, or where necessary to establish, exercise or defend legal claims or to protect the rights, safety or security of Coach, our users or others. Where a legal process compels disclosure, we will notify you where we are permitted to do so.

Corporate transactions. If GreyMatter Labs LDN LTD is involved in a merger, acquisition, financing, reorganisation or sale of all or part of its business or assets, relevant personal information may be disclosed, under confidentiality restrictions, to advisers and any counterparty or acquirer, which will remain bound by this policy or give you notice before changing it.

10. International transfers

Our servers, database and logs are hosted in the United States, and our providers may process personal information there or in other locations. Where we make a transfer that is restricted under UK data protection law, we rely on an appropriate transfer mechanism for that recipient and transfer — such as UK adequacy regulations (including the UK Extension to the EU–US Data Privacy Framework where it applies), the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, or an applicable exception — and, where required, carry out a transfer risk assessment and apply supplementary measures.

You may request further information about the mechanism we rely on, or a copy of the relevant safeguards (with commercial terms redacted), at privacy@coach-app.ai.

11. Retention

We keep your account information, training history, conversations, memory notes and health information for as long as you hold an account, because they are used to provide your training history, progression and continued coaching. When you delete your account, we delete the active copies of that information, subject to the following:

• Feedback you have submitted is kept after your account deletion with any personal identifying information removed and it is not capable of being linked to you.
• Backups are kept for disaster recovery for a limited period and are then overwritten. A copy of deleted information may persist in a backup until it is overwritten, and backups are not used to recreate a deleted account.
• Providers' own retention, which we do not set — principally the AI provider's abuse-monitoring window (Section 4) and the workplace messaging provider's retention of feedback.

We may also delete or anonymise information that is no longer needed, including accounts that have been inactive for an extended period, and we will retain information where necessary to comply with a legal obligation or in connection with a legal claim.

12. Your rights (United Kingdom)

Under UK data protection law, you have the following rights in relation to your personal information. These rights may not apply in every circumstance, and we may need to verify your identity before acting on a request.

• The right to be informed — to receive clear information about how Coach collects, uses, shares and retains your personal information.
• The right of access — to obtain a copy of the personal information we hold about you. You can download your data in the app or make a written data subject access request specifying the information you would like to receive.
• The right to rectification — to ask us to correct inaccurate personal information or complete information that is incomplete. You can also manage and correct Coach's memory notes in the app.
• The right to erasure — in certain circumstances, to ask us to delete your personal information where it is no longer needed, where you withdraw consent and no other lawful basis applies, or where the processing is unlawful. You can permanently delete your Coach account in the app, subject to the limited retention exceptions in Section 11.
• The right to restrict processing — in certain circumstances, to ask us to limit how we use your personal information. We may continue to store it while the restriction applies.
• The right to data portability — where applicable, to receive personal information you provided to us in a structured, commonly used and machine-readable format, or to ask us to transmit it to another organisation where technically feasible.
• The right to object — to object to processing based on our legitimate interests where your rights and interests outweigh our reasons for the processing. You also have an absolute right to object to direct marketing; Coach does not currently use your personal information for direct marketing.
• The right to withdraw consent — where we rely on consent, to withdraw it at any time. Withdrawal does not affect processing carried out before consent was withdrawn. As explained in Section 5, you can withdraw the health-information consents required for a Coach account by deleting your account.
• The right to complain — to complain to the Information Commissioner's Office if you believe we have processed your personal information improperly or unlawfully. You are not required to contact us before making a complaint.

In the app, you can:

• Download your data — Profile → Your data → Download my data exports the information we hold, including your profile, training history, conversations and memory notes.
• Manage Coach's memory — Profile → Your data → What Coach remembers lets you delete a note or add your own correction (Section 3).
• Delete your account — Profile → Your data → Delete account. Deletion is permanent and cannot be reversed.

To exercise any of these rights, or if the in-app tools do not resolve your request, contact our data protection team in writing at privacy@coach-app.ai and describe the right you wish to exercise and the information concerned. You are not required to pay any charge for exercising your rights. We have one month to respond to you. We may ask for information to verify your identity, and an authorised agent may act for you where suitable written authority is provided.

Cancelling your subscription is a separate step, done through Apple; deleting your Coach account does not cancel Apple billing.

13. United States

We extend the same core rights to all users. This section describes them under US state privacy law and sets out the disclosures those laws require. If you are resident in Washington, Nevada or Connecticut, please also read our Consumer Health Data Privacy Policy, which addresses consumer health data in the form those states require.

13.1 Categories of personal information

Using the categories defined in the California Consumer Privacy Act:

We do not collect precise geolocation, biometric identifiers, or professional, employment or education information as part of the service.

13.2 Sensitive personal information

We use health information solely to provide the coaching you have requested, to secure the service and to comply with law — purposes for which the right to limit its use does not require a further option. We do not use it to profile you for advertising or to build a picture of you for anyone else.

13.3 Sale, sharing and advertising

We do not sell or share personal information, and we do not process it for targeted or cross-context behavioural advertising, as those terms are defined by California law, and have not done so in the preceding 12 months. We do not sell consumer health data. Coach contains no advertising and no cross-site tracking. If you are a Nevada resident, you may still submit a request that we not sell your covered information, at privacy@coach-app.ai.

13.4 Your rights

Subject to your state of residence, you may know, access, correct, delete and (for sensitive information) limit the use of your personal information, and appeal a decision on any request. Access, correction of Coach's notes, and deletion are available in the app (Section 12); other requests go to privacy@coach-app.ai. We do not discriminate against you for exercising these rights.

Appeals. If we refuse a request, you may appeal by replying to our decision or writing to privacy@coach-app.ai with "Appeal" in the subject line. We will notify you of the outcome, with reasons, within 45 days, and tell you how to contact your state Attorney General if we maintain the refusal.

14. Age

You must be at least 18 to hold a Coach account. Coach asks for your date of birth during onboarding and will not let you continue if it places you under 18. We do not knowingly collect information from anyone under that age; if you believe an account belongs to someone under 18, contact privacy@coach-app.ai and we will delete it.

15. Our website

The pages at coach-app.ai set no cookies and load no third-party scripts, fonts or other embedded resources, and they do not track visitors across other websites or services. Our content-delivery provider maintains its own operational and security logs, which may include IP address and user-agent information. Selecting an App Store link may disclose coach-app.ai as the referring site to Apple.

Coach does not respond to "Do Not Track" browser signals, because it does not track you across third-party sites. We will update this section before introducing any website analytics.

16. Security

Sign-in is passwordless (Apple ID, Google, or a one-time email code). Traffic between the app and our servers is encrypted in transit, requests are authenticated and scoped to your own account, and data is encrypted at rest by our hosting provider, with access restricted to the application and to staff who require it. No system is completely secure; if a personal-data breach occurs, we will investigate, take appropriate action, and notify affected individuals and regulators where the law requires.

17. Complaints

To complain about how we handle your information, write to privacy@coach-app.ai with "Complaint" in the subject line, and we will respond. You are not required to contact us first.

In the United Kingdom you may complain to the Information Commissioner's Office (Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF; 0303 123 1113; ico.org.uk). In the United States, you may contact the Attorney General of the state whose privacy law applies to you; the Consumer Health Data Privacy Policy gives the routes relevant to Washington, Nevada and Connecticut. Contacting us does not affect your right to approach a regulator or seek a legal remedy.

18. Changes to this policy

We may update this policy to reflect changes in the service, the law, our providers or our processing. We will update the effective date, and the previous version will remain available on request. Where a change is material — such as a new category of information, recipient or purpose — we will notify you in the app before it takes effect, and obtain your consent where the law requires it.

19. Contact

GreyMatter Labs LDN LTD 128 City Road, London EC1V 2NX, United Kingdom Privacy: privacy@coach-app.ai Support: support@coach-app.ai