PRIVACY POLICY

    Last updated February 20, 2026

    This Privacy Notice for 10D Labs, LLC ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

    • Visit our website at https://forgetrainer.ai or any website of ours that links to this Privacy Notice
    • Download and use our mobile application (Forge), or any other application of ours that links to this Privacy Notice
    • Engage with us in other related ways, including any marketing or events

    Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@forgetrainer.ai.

    SUMMARY OF KEY POINTS

    This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

    What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

    Do we process any sensitive personal information? We collect health and fitness-related information (such as injuries, physical limitations, and body measurements) to provide personalized fitness training. Our AI systems also generate profiles and insights about your fitness patterns based on your interactions. Some of this information may be considered "special" or "sensitive" in certain jurisdictions. We process this information only to deliver our fitness training Services and treat it with additional care.

    Do we use artificial intelligence? Yes. Our Services are powered by AI that generates personalized workout plans, provides coaching responses, analyzes your progress, and builds a coaching profile to improve your experience over time. Your data is processed by third-party AI service providers to deliver these features. Learn more about how we use AI to process your information.

    Do we receive any information from third parties? We may receive limited information from third-party services you use to interact with us. For example, if you sign in using a third-party authentication provider (such as Google Sign-In), we receive your name, email address, and profile picture from that provider. We may also receive subscription status information from payment and subscription management services to verify your access to premium features.

    How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

    In what situations and with which parties do we share personal information? We may share information in specific situations and with specific categories of third parties, including AI service providers, analytics providers, and infrastructure providers. Learn more about when and with whom we share your personal information.

    How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

    What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

    How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

    Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

    TABLE OF CONTENTS

    1. WHAT INFORMATION DO WE COLLECT?
    2. HOW DO WE PROCESS YOUR INFORMATION?
    3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
    4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
    5. HOW LONG DO WE KEEP YOUR INFORMATION?
    6. HOW DO WE KEEP YOUR INFORMATION SAFE?
    7. DO WE COLLECT INFORMATION FROM MINORS?
    8. WHAT ARE YOUR PRIVACY RIGHTS?
    9. CONTROLS FOR DO-NOT-TRACK FEATURES
    10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
    11. DO WE MAKE UPDATES TO THIS NOTICE?
    12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
    13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

    1. WHAT INFORMATION DO WE COLLECT?

    Personal information you disclose to us

    In Short: We collect personal information that you provide to us.

    We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

    Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

    • Email addresses
    • Name
    • Date of birth
    • Biological sex
    • Profile picture
    • Fitness goals and workout preferences
    • Experience level
    • Equipment access (gym equipment available to you)
    • Workout availability (days and times you prefer to exercise)
    • Activity level and sleep quality information
    • Body measurements (such as weight, height, and other physical measurements)
    • Workout logs and exercise history
    • Personal records and achievements
    • Difficulty ratings and notes you provide after workouts
    • Health-related information you provide (such as injuries, joint pain, or physical limitations)
    • Messages exchanged with your AI personal trainer
    • Voice recordings (if you choose to use speech-to-text features to communicate with your AI trainer). Speech-to-text conversion is performed by your device's operating system. We receive only the resulting text transcription, not the original audio recording.
    • Feedback submissions, including optional screenshots and device information, that you send through the App's feedback feature

    Health and Fitness Information. Some of the information we collect, such as information about injuries, physical limitations, and body measurements, may be considered health-related information. We collect this information solely to provide you with personalized fitness training and workout recommendations. We treat this information with additional care and use it only to improve your experience with our Services.

    Information derived by our AI systems

    In Short: Our AI creates coaching profiles and insights about you to deliver personalized training.

    To provide personalized fitness coaching, our AI systems analyze your interactions, workout performance, and the information you provide to build and maintain a coaching profile. This derived information may include:

    • Coaching memories and preferences: Summaries of your goals, communication preferences, exercise likes and dislikes, training history, and other information your AI trainer learns from conversations with you
    • Fitness knowledge graph: Relationships between your injuries, exercises, muscle groups, and equipment preferences that help your AI trainer provide safe and relevant recommendations
    • Progress analysis: Trend summaries, adherence patterns, performance insights, and coaching triggers (such as detecting a strength plateau or a change in your training consistency)
    • Conversation context: Compressed summaries of past conversations used to maintain coaching continuity
    • Vector representations: Mathematical representations of your coaching interactions used to help the AI recall relevant context

    This information is generated automatically by our AI systems based on your use of the Services. It is used solely to improve the quality and personalization of your AI coaching experience and is deleted when you delete your account.

    Information received from third parties

    In Short: We may receive limited information from third-party services you use to interact with us.

    We may receive personal information about you from third parties, including:

    • Authentication providers: If you create an account or sign in using a third-party service (such as Google Sign-In), we receive your name, email address, and profile picture from that provider.
    • Subscription management services: We receive information about your subscription status, billing period, and entitlement from subscription management providers to verify your access to premium features.

    Information automatically collected

    In Short: Some information -- such as your device information, usage data, and interaction recordings -- is collected automatically when you use our Services.

    We automatically collect certain information when you visit, use, or navigate our Services. This information does not reveal your specific identity but may include device and usage information, such as:

    • Device identifiers (such as your device ID and app instance ID)
    • Device information (such as device type, operating system, and version)
    • Usage data (such as features used, actions taken, screens visited, and time spent in the app)
    • Session recordings and touch interaction data (we may record how you interact with the App, including screen views and touch gestures, to understand usage patterns and improve the product)
    • Push notification tokens (to send you notifications if you have enabled them)
    • App version and update information

    This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

    Session Recordings. We use product analytics tools that may record your interactions with the App, including the screens you view and how you navigate the interface. These recordings help us understand how users interact with the App and identify areas for improvement. Session recordings may capture information displayed on screen, including health and fitness data. We use these tools to improve our Services, not to identify or track individual users.

    All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

    2. HOW DO WE PROCESS YOUR INFORMATION?

    In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

    We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

    • To provide AI-powered fitness coaching. We process your profile information, fitness data, health information, conversation history, and workout performance to generate personalized workout plans, provide coaching responses, and adapt your training over time. This involves sending relevant portions of your data to third-party AI service providers for processing.
    • To generate and adapt workout plans. We process your fitness goals, experience level, equipment access, injury information, workout history, and performance data to create and continuously adjust personalized workout programming.
    • To analyze your progress and provide insights. We process your workout logs, performance data, and historical trends to detect patterns, identify plateaus, track achievements, and generate progress reports.
    • To maintain AI coaching context. We process your conversations, preferences, and training history to build and maintain a coaching profile so your AI trainer can remember your context and provide consistent, personalized guidance across sessions.
    • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
    • To manage subscriptions and AI usage. We process information about your subscription status and track your AI feature usage to manage access to Services features and enforce usage limits.
    • To improve our Services through analytics. We process usage data, interaction patterns, and session recordings to understand how users engage with the App, identify issues, and improve the user experience.
    • To process feedback and support requests. We process feedback submissions, including any screenshots you provide, to investigate issues and improve the Services.
    • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
    • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
    • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

    Automated Processing and AI Decision-Making

    Our Services rely on automated processing, including AI-generated decisions, to deliver personalized fitness coaching. Specifically, our AI systems automatically:

    • Select exercises and design workout plans based on your goals, experience, equipment, and injury information
    • Determine target weights, repetitions, and set volumes based on your performance history
    • Adjust future workouts based on your difficulty ratings and actual vs. target performance
    • Generate coaching feedback and recommendations
    • Detect training patterns such as plateaus, adherence changes, and milestone achievements
    • Build and update your coaching profile based on your conversations and behavior

    These automated decisions directly affect the workout plans and coaching you receive. They are based on the information you provide and your usage of the Services. You can influence these decisions at any time by communicating with your AI trainer through the chat feature, updating your profile and preferences, or contacting us to request human review of any AI-generated recommendation.

    Batch Processing

    We run scheduled automated processes to maintain and improve the quality of your AI coaching experience. These may include periodic analysis of your training trends, consolidation of your coaching profile, and cleanup of outdated information. These processes run on our servers using the same third-party AI service providers described in this Notice.

    In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

    If you are located in the EU or UK, this section applies to you.

    The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

    • Performance of a Contract. We process your personal information to provide the AI fitness coaching Services you have subscribed to, including generating workout plans, providing coaching responses, maintaining your coaching profile, and tracking your progress. This processing is necessary to deliver the Services under our agreement with you.
    • Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. In particular, we rely on your explicit consent to process health-related and sensitive fitness data. You can withdraw your consent at any time. Learn more about withdrawing your consent.
    • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
      • Send users information about special offers and discounts on our products and services
      • Understand how our users use our products and services so we can improve user experience
      • Analyze usage patterns and session recordings to improve the App
    • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
    • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

    If you are located in Canada, this section applies to you.

    We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

    In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

    • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
    • For investigations and fraud detection and prevention
    • For business transactions provided certain conditions are met
    • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
    • For identifying injured, ill, or deceased persons and communicating with next of kin
    • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
    • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
    • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
    • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
    • If the collection is solely for journalistic, artistic, or literary purposes
    • If the information is publicly available and is specified by the regulations
    • We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

    4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

    In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

    We may need to share your personal information in the following situations:

    Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

    Third-Party Service Providers. We share your information with the following categories of third-party service providers to perform services on our behalf:

    • AI and machine learning service providers that process your data to generate workout plans, coaching responses, progress analysis, and other AI-powered features. This includes providers of language model inference, text embedding, AI workflow orchestration, and AI system monitoring and observability. Relevant portions of your profile, fitness data, conversation history, and workout performance may be shared with these providers to deliver our AI coaching features.
    • Analytics and product improvement providers that help us understand how our Services are used, including providers of usage analytics, session recording, and interaction analysis
    • Subscription and payment management providers that manage your subscription status, billing periods, and entitlement verification. These providers receive your user identifier and subscription status but do not receive your credit card or payment information, which is handled directly by Apple or Google.
    • Paywall and feature management providers that manage access to premium features based on your subscription status
    • Cloud infrastructure and database providers that host, store, and process your data securely, including your account information, workout data, AI coaching profiles, and conversation history
    • Authentication providers that facilitate account creation and login, including third-party sign-in services
    • Push notification services that deliver workout reminders and other notifications to your device
    • App update and distribution services that deliver software updates to the App on your device

    These service providers have access to your personal information only to perform specific tasks on our behalf and are obligated not to disclose or use it for any other purpose. We do not sell your personal information to any third party.

    AI Service Provider Data Practices. When your data is processed by third-party AI service providers to deliver our coaching features, it is subject to those providers' data handling practices. We select providers whose terms prohibit the use of customer data for training their AI models. We do not train our own AI models on your personal data, and we do not intentionally provide your data to any third party for the purpose of training general-purpose AI models.

    5. HOW LONG DO WE KEEP YOUR INFORMATION?

    In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

    We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

    While your account is active: We retain all information described in this Notice for as long as you maintain an account with us. AI coaching profiles, conversation history, and workout data are maintained to provide continuity and personalization in your training experience. Older conversation messages may be summarized and compressed to manage storage while preserving coaching context.

    AI-derived data retention: Coaching memories and profile information generated by our AI systems are maintained while your account is active. Certain low-relevance AI observations may be archived (excluded from active use but not deleted) after approximately 90 days. Outdated injury and health context records may be periodically removed as part of routine maintenance.

    When you delete your account: Upon account deletion, we delete your identifiable personal information from our active databases, including your profile, body measurements, conversation history, AI coaching profiles and memories, training programs, and workout plans. See Section 13 for full details on what is deleted and what may be retained.

    When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

    6. HOW DO WE KEEP YOUR INFORMATION SAFE?

    In Short: We aim to protect your personal information through a system of organizational and technical security measures.

    We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These measures include:

    • Encryption of sensitive authentication credentials on your device using platform-provided secure storage (such as iOS Keychain and Android Keystore)
    • Secure transmission of data between the App and our servers
    • Access controls that restrict data access to authorized personnel and systems
    • Row-level security policies on our database to ensure users can only access their own data

    However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

    Data Breach Notification. In the event of a data breach that affects your personal information, we will notify you and any applicable regulatory authorities as required by applicable law. We will make reasonable efforts to notify affected users promptly via email and/or through the App.

    7. DO WE COLLECT INFORMATION FROM MINORS?

    In Short: We do not knowingly collect data from or market to anyone under 18 years of age.

    The Services are intended for users who are at least 18 years of age. We do not knowingly collect, solicit data from, or market to anyone under 18, nor do we knowingly sell such personal information. The App verifies your date of birth during account setup and will not permit users under 18 to create an account. If we learn that personal information from anyone under the age of 18 has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from anyone under age 18, please contact us at support@forgetrainer.ai.

    8. WHAT ARE YOUR PRIVACY RIGHTS?

    In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

    In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

    We will consider and act upon any request in accordance with applicable data protection laws.

    If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

    If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

    Automated Decision-Making. Our AI systems make automated decisions that affect the workout plans and coaching you receive, as described in Section 2. These decisions are an integral part of the AI coaching service you have subscribed to and are necessary to deliver the Services. You can influence AI decisions by chatting with your trainer, updating your preferences, or modifying individual workouts. If you believe an AI-generated recommendation is inappropriate or you wish to request human review of an automated decision, you may contact us at support@forgetrainer.ai.

    Data Portability and Export. You have the right to receive a copy of the personal data we hold about you in a structured, commonly used format. The App provides a data export feature that allows you to download your personal information, including your profile, workout history, and other account data. You may also request a data export by contacting us.

    Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

    However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

    Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you -- for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

    Account Information

    If you would at any time like to review or change the information in your account or terminate your account, you can:

    • Log in to your account settings and update your profile information
    • Use the data export feature to download your data
    • Delete your account through the App settings or by contacting us
    • Contact us using the contact information provided

    Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. See Section 13 for details on what is deleted and what may be retained.

    If you have questions or comments about your privacy rights, you may email us at support@forgetrainer.ai.

    9. CONTROLS FOR DO-NOT-TRACK FEATURES

    Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

    California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

    10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

    In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

    Categories of Personal Information We Collect

    The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?"

    CategoryExamplesCollected
    A. IdentifiersContact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account nameYES
    B. Personal information as defined in the California Customer Records statuteName, contact information, education, employment, employment history, and financial informationYES
    C. Protected classification characteristics under state or federal lawGender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic dataYES
    D. Commercial informationTransaction information, purchase history, financial details, and payment informationYES
    E. Biometric informationFingerprints and voiceprintsNO
    F. Internet or other similar network activityBrowsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisementsYES
    G. Geolocation dataDevice locationNO
    H. Audio, electronic, sensory, or similar informationImages, session recordings of app interactions, and audio recordings created in connection with our business activitiesYES
    I. Professional or employment-related informationBusiness contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with usNO
    J. Education InformationStudent records and directory informationNO
    K. Inferences drawn from collected personal informationInferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences, characteristics, fitness patterns, and coaching needs. This includes AI-generated coaching profiles, progress analysis, and behavioral insights.YES
    L. Sensitive personal InformationHealth-related information including injuries, physical limitations, body measurements, fitness data, and biological sexYES

    We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

    • Receiving help through our customer support channels;
    • Participation in customer surveys or contests;
    • Submitting feedback or bug reports through the App; and
    • Facilitation in the delivery of our Services and to respond to your inquiries.

    We will use and retain the collected personal information as needed to provide the Services or for:

    • Category A - As long as the user has an account with us
    • Category B - As long as the user has an account with us
    • Category C - As long as the user has an account with us
    • Category D - As long as the user has an account with us, plus any period required for tax and legal compliance
    • Category F - As long as the user has an account with us
    • Category H - Session recordings retained for up to 90 days; profile pictures retained as long as the user has an account
    • Category K - As long as the user has an account with us; AI-derived profiles deleted upon account deletion
    • Category L - As long as the user has an account with us

    Sources of Personal Information

    Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

    How We Use and Share Personal Information

    Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

    Will your information be shared with anyone else?

    We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

    We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

    We have not sold or shared (as defined under California law) personal information to third parties for monetary or other valuable consideration in the preceding twelve (12) months. We disclose limited information to service providers (such as AI providers, cloud hosting, and payment processors) solely to operate our Services, as described in the section "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?." These disclosures are made for business purposes under service provider agreements and do not constitute "selling" or "sharing" under California law. If you are a California resident and wish to opt out of any future sale or sharing of your personal information, you may contact us at support@forgetrainer.ai.

    Your Rights

    You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

    • Right to know whether or not we are processing your personal data
    • Right to access your personal data
    • Right to correct inaccuracies in your personal data
    • Right to request the deletion of your personal data
    • Right to obtain a copy of the personal data you previously shared with us
    • Right to non-discrimination for exercising your rights
    • Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

    Depending upon the state where you live, you may also have the following rights:

    • Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
    • Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
    • Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
    • Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
    • Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
    • Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
    • Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

    How to Exercise Your Rights

    To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at support@forgetrainer.ai, or by referring to the contact details at the bottom of this document.

    Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

    Request Verification

    Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

    If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

    Appeals

    Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at support@forgetrainer.ai. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

    11. DO WE MAKE UPDATES TO THIS NOTICE?

    In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

    We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

    12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

    If you have questions or comments about this notice, you may email us at support@forgetrainer.ai or contact us by post at:

    10D Labs, LLC 109 W Fortune St. #2109 Tampa, FL 33602 United States

    13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

    Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

    Reviewing and exporting your data: The App provides a data export feature that allows you to download a copy of your personal information. You may also request a copy by emailing us at support@forgetrainer.ai.

    Updating your data: You can update your profile information, body measurements, training preferences, and other account details at any time through the App settings.

    Deleting your data: You can delete your account and associated data at any time through the App settings, or by emailing us at support@forgetrainer.ai. For full details on how to delete your account and what data is affected, please visit https://forgetrainer.ai/delete-account.

    What is deleted when you delete your account:

    • Profile information (name, email, date of birth, biological sex)
    • Body measurements and weight history
    • Workout plans and training programs
    • AI conversation history and chat messages
    • AI coaching profiles, memories, and knowledge graph data
    • Personal records
    • Profile picture and any submitted feedback screenshots
    • Training preferences and goals

    What may be retained after account deletion:

    • Anonymized workout and usage data: Workout session records and AI usage logs are anonymized (your user identifier is removed) and may be retained for product analytics and service improvement. This data cannot be linked back to you.
    • Third-party service records: Some data that has already been transmitted to third-party service providers (such as subscription management services and analytics providers) may persist in those systems according to their own retention policies. We make reasonable efforts to propagate deletion requests to our service providers where technically feasible.
    • Purchase records: Apple and Google retain transaction history for tax and refund purposes. We cannot delete this data. Contact Apple or Google directly regarding their records.

    To request to review, update, or delete your personal information, please email us at support@forgetrainer.ai.