Fitlumio
Fitlumio Privacy Policy
Draft version 0.1 · to be reviewed by a lawyer before publication
This translation is provided for convenience; in case of differences the Polish version prevails.
1. Data controller
The controller of your personal data is Rafał Uzdowski. Contact regarding data: [email protected], postal address: ul. Lodowa 54, 92-313 Łódź, Poland.
2. What data, for what purpose and on what legal basis
| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| Apple/Google account identifier, e-mail address (may be hidden by Apple) | Sign-in and account | Art. 6(1)(b) (contract) |
| Workouts, sets, weights, distance, personal records, plans | Plans, statistics, web panel, cloud backup | Art. 6(1)(b) |
| Health data: heart rate, sleep, HRV (Apple Health) | Assessment of readiness and training load | Art. 9(2)(a) (explicit consent) |
| Questions to Lumio and workout summary | Answers from the AI coach | Art. 6(1)(a) and Art. 9(2)(a) (consent) |
| E-mail address for the newsletter | Tips and news | Art. 6(1)(a) (consent) |
| Technical logs (IP address, time, browser) | Security, protection against abuse | Art. 6(1)(f) (legitimate interest) |
We do not use health data for advertising, we do not sell it and we do not share it for marketing purposes.
3. Recipients of data
- Cloudflare, Inc.: servers and database (storage in the EU).
- Google LLC: Google sign-in (if you choose it) and, only with your consent to Lumio AI: the Gemini model that generates Lumio's answers and Google Cloud Text-to-Speech, which reads these answers aloud in a natural voice (Text-to-Speech receives only the text of the answer, without any data about you).
- Apple Inc.: Sign in with Apple, Apple Health on your device.
Data is transferred outside the EEA on the basis of standard contractual clauses or the EU-US Data Privacy Framework.
4. How long
Account data and workouts: until the account is deleted. Sign-in sessions: up to 90 days. Technical logs: 30 days. Backups are purged within 30 days of account deletion. Conversations with Lumio are stored only on your phone.
5. Your rights
You have the right to access your data, to rectification, erasure, restriction of processing, data portability (download in JSON/CSV in the app and in the panel), to object, and to withdraw consent at any time (Profile → Privacy and data), without affecting the lawfulness of processing carried out before the withdrawal. You can delete your account in the app or in the web panel. You have the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw, Poland).
6. Age
Fitlumio is intended for persons who are at least 16 years old.
7. Cookies
The website uses only a strictly necessary sign-in session cookie. We do not use analytics or advertising cookies.
8. Changes
We will inform you about material changes in the app and ask you to accept them again if required.