To use certain applications and websites, we may request that you provide your name, email address, weight, height, fitness level, areas for improvement, and preferred foods. We may also ask other onboarding questions based on the app or web products you select within our ecosystem (e.g., mental health information may be required to use certain mental health features). In some apps, you may skip some onboarding questions by selecting 'Skip' or a similar option.
Additionally, we collect the following information from your device: language settings, IP address, time zone, device type and model, device settings, operating system, and other technical information. This information is necessary to provide our services (e.g., to render certain elements of the product), analyze how customers use our app (e.g., to determine if customers are using features we have released), and serve ads. In most cases, you can influence the processing of such information by restricting it through the privacy features provided on our website and/or app.
Please refer to our privacy policy below to learn more about the data we collect and what we do with it (see Section 2), and what data privacy rights are available to you (see Section 4). We are committed to providing various privacy management features and rights based on the region in which you access our services and the product you select. Examples include:
- Influencing online tracking through the electronic privacy settings on our app or website.
- Opting out of data sales/sharing (in the meaning of certain U.S. laws).
- Requesting the deletion of your data and account.
- Exercising other privacy rights.
If available, these features will be prominently displayed in the product's footer, menu, or profile section. We aim to offer most of these rights directly through the privacy features available to you, allowing you to access them via simple, user-friendly service interactions. If you have difficulty locating these features or if they are not available, please request assistance from us.
For any unanswered questions or to exercise your privacy rights, please contact us at soundgym@soundgym.io.
Privacy Policy
This Privacy Policy explains and lists the personal data collected when you use our mobile applications, websites, and the services provided through them (hereinafter referred to as the "App" or "Service"), as well as how this personal data is processed to ensure transparency. By using the Service, you (i) acknowledge that you have read, understood, and agree to this Privacy Policy and the data processing described herein, and (ii) confirm that you are at least 12 years old. If you are under 18 years old, you confirm that you have obtained the explicit consent of a parent or legal guardian to use the Service. The Service does not knowingly collect personal information from users under the age of 12. If we become aware that personal information from a user under the age of 12 has been collected without verifiable parental consent, we will take steps to delete such information promptly. If you do not agree to this or cannot make such a confirmation, you are not permitted to use our Service. In such cases, you must (a) delete your account and request the deletion of your data, (b) cancel your subscription through the features provided by Apple (if using iOS), Google (if using Android), or any other app stores as applicable, or through our website if purchased directly from us, and (c) delete the app from your device. For users aged 12 to 17, parental or guardian consent is required for the above actions. Parents or legal guardians of users aged 12 to 17 are encouraged to supervise their child's use of the Service and review the Service's features and content.
All translations of this Privacy Policy into other languages are provided solely for your convenience and transparency. In the event of any differences in meaning or interpretation between the English version of this Privacy Policy and any other translations, the English version shall prevail, and only the original English text is legally binding.
1. Categories of Personal Data We Collect
The data we process includes the following:
- Data you provide directly to us (e.g., when you select areas for improvement, send us an email, or interact with our coaches),
- Data we receive from third parties about you (e.g., when you log in via Apple, or when you allow us to access HealthKit data),
- Data automatically collected when you use our services (e.g., your IP address provided through cookies or SDK technology).
Data You Provide Directly to Us
Identifiers
This may include your name, phone number, and email address. You provide this information when you register for the Service, purchase physical products from us, subscribe to our newsletter, or contact us in other ways.
Onboarding and Product Data
You provide this category of data when you register for the Service, go through the onboarding process, or use the Service. This category includes the following:
- General information about you (e.g., age, birthday, gender, etc.).
- Health and fitness information. This may include your height, weight, workout-related data, preferred meditation and breathing methods, sleep patterns, types and durations of physical activities you participate in, and more. We may also ask for information regarding your fitness level and dietary preferences, and request options that allow you to track your food and beverage intake. We use some of this data to personalize your experience as part of the services we offer.
- Special health data. Some of the information we collect may be considered special category personal data or sensitive data under certain data protection laws. For example, if we ask whether you need meal planning for diabetes or whether you want to subscribe to a special program for limb loss, we will make every effort to seek your consent for processing this data.
Commercial Information
If you pay for our services, you will need to provide financial account data, such as credit card numbers, to third-party service providers that handle payment processing on our behalf. While we do not collect, store, or have access to full credit card data, we may receive limited information, such as secure tokens that reflect your payment method, product or service purchase data, transaction dates, amounts, the type of payment method used, and partial card numbers.
Conversations with the AI Chatbot Coach
As part of our premium service, we provide the opportunity to interact with an AI Chatbot Coach. During these interactions, we process the text of conversations between you and the AI Chatbot Coach. This category includes all the information you provide during such conversations, including your progress, feedback, goals, diet photos, or other details discussed.
Voice Data from AI Voice Coaching
As part of our premium service, we may offer AI-powered voice coaching sessions ("Voice Coaching"). During Voice Coaching sessions, the following data is processed:
- Voice input data: Your voice is captured through your device's microphone and transmitted in real-time to third-party AI service providers (such as Google) for processing. Voice input data is used solely to generate real-time AI responses during the coaching session and is not stored or retained by us or our third-party AI service providers after the session ends.
- Voice coaching session metadata: We may collect metadata related to your Voice Coaching sessions, such as session duration, time and date of sessions, and session frequency. This metadata is used to improve the Service and your coaching experience.
- Contextual data: To provide personalized coaching, your existing profile data (such as fitness goals, dietary preferences, and activity history) may be shared with the AI service provider during the session to generate relevant responses. This contextual data is transmitted in real-time and is not separately stored by the AI service provider.
Voice Coaching requires you to grant microphone access permission on your device. You may revoke this permission at any time through your device settings, which will prevent you from using Voice Coaching but will not affect other features of the Service. We do not use your voice data for advertising, marketing, or any purpose other than providing real-time Voice Coaching responses.
Comments Provided with Your Requests
You may also provide personal information by using our "Contact Us" form or sending emails to our email address (processed by our data processing providers as mentioned in Section 3). This information may include any comments you provide when submitting your requests.
Data Provided by Third Parties
Apple ID Account
If you log in using Apple and register an account in the app, we collect personal information from your Apple ID account. This data may include, in particular, your name and verified email address. You can choose to share your real email address or an anonymous email via Apple's email relay service, and Apple will display detailed personal information on the Apple login screen. For more information about logging in with your Apple account, see Apple's documentation.
Apple Health Kit (and Apple Motion & Fitness API) or Google Fit (collectively "Health Apps")
If you provide explicit approval on your device, we may receive (read) and/or record (share) data related to your activities through the Health Apps. In some of our apps, you can allow us to read (receive) information from the Health Apps, such as step count, distance traveled, weight, dietary energy, and other data selected by you on the consent screen. If you grant permission for us to record (share) data with the Health Apps, we will transmit information about your workouts, weight, and dietary energy (calories consumed). The scope of the data included in the Health Apps is shown to you via the default Apple or Google pop-up screens, which we cannot control.
In this case, your data is subject to the respective Health App's policy, so please review the privacy policy of the Health App before deciding to share data. You may revoke access to read or record data from the Health Apps at any time via the Health Apps themselves.
Data We Collect Automatically
Online Activity
We log your interactions with our services. For example, we record which areas of the interface, features, content, workouts, workout times and durations, meditation activities, app usage frequency, app usage times, progress on training and meditation programs, and subscription orders you interact with.
Device and Geolocation Data
We collect data from your mobile device, such as language settings, IP address, time zone, device type and model, device settings, operating system, internet service provider, mobile carrier, hardware ID, and Facebook ID. For certain products, if you agree to share geolocation data (e.g., for running routes), the app may also receive that data.
Advertising ID
We collect your Apple Advertising Identifier ("IDFA") or Google Advertising ID ("AAID") (depending on your device operating system). Generally, you can reset these values through your device's operating system settings (though we do not control this).
Cookies and Similar Tracking Technologies
Our products use technologies (e.g., cookies, SDKs) that process your data to improve the user experience, optimize ads, and analyze traffic. These technologies are activated when you interact with our service, visit our website, use our app, or enable certain features like chat. Deactivating these technologies may affect some functionalities but will not prevent the use of our products.
Additionally, we and our partners may use targeting technologies to personalize ads and display them at appropriate times. When these technologies are activated, you may see ads for our products on social media platforms as you interact with our website or app. These activities may be used to measure the effectiveness of our ad campaigns. We respect your privacy and provide options to reject data processing that is not necessary for the service you requested.
Specifically, the types of tracking technologies we use include:
- Essential: Certain technologies are required for our products and their features to function properly. They are typically activated when you visit our website or launch the app, and they help us (i) remember your preferences as you browse our products, (ii) load content you requested quickly, (iii) enhance the security of our products, and (iv) enable other features of our products. Some of these technologies may also be activated when you enable features like chat or request customer support.
- Functional: We use functional technologies to personalize and enhance your experience. These technologies help us remember your choices (e.g., customized design settings or long-term language preferences). They also allow us to store settings, keep you logged in for extended periods, or save shopping cart selections, providing you with a more consistent user experience. Deactivating these technologies may cause certain features to malfunction, but it will not prevent you from using our products.
- Performance: We use performance technologies to process information about how you and others interact with our products. This helps us understand user engagement with our products and features, identify preferences and dislikes, and analyze user behavior to make decisions about future features. Examples include counting the number of visits and identifying traffic sources, identifying the most preferred sections or features, and analyzing user preferences to inform decisions on developing new features. Deactivating these performance technologies will prevent us from receiving certain information we process for analytical purposes.
- Targeting: We and our partners use targeting technologies to personalize ads and display them at appropriate times. For example, if these technologies are enabled and you interact with our website or app, you may see ads for our products in your social media feed. Additionally, these technologies allow us to measure the effectiveness of ad campaigns and provide you with more relevant ads. Rejecting these targeting technologies may result in less relevant ads being displayed to you, and you may miss out on benefits offered during specific promotional periods. It will also affect the accuracy of our ad performance measurements.
2. Purpose and Legal Basis for Data Processing
We collect and use your data primarily to provide our services, enhance the quality of our fitness and health services, and continuously improve. We also use this data to attract new customers. Below, we provide clear examples of how we use your information in more detail.
Additionally, some of the information we collect regarding onboarding and product data may be considered special category personal data or sensitive data under certain data protection laws. For example, if we ask whether you require meal planning for diabetes, we will make every effort to seek your consent for processing this data. However, please note that if the data necessary to provide the service is classified as special category personal data, we will require your consent before offering access to the service. Without this consent, it will not be possible to provide access to our services.
| Purpose of processing | Description and examples | Categories of personal data | Lawful basis |
|---|---|---|---|
| To provide our Service and administer your account | Verifying your identity, email verification, enabling seamless access and use, preventing or addressing errors or technical issues, and customizing your experience (e.g., a nutrition plan with only vegetarian products). Also includes responding to technical or customer support requests and sending notifications about performance, security, payment transactions, or notices regarding our Terms or this Privacy Policy. | All categories | Performing our contract with you. Or consent if the data relates to a special category of personal data in a covered jurisdiction. |
| To communicate with you regarding your use of our Service | For example, push notifications, reminders and motivational messages, password resets, or account updates. To opt out of push notifications, change your device settings. We may also communicate about important updates, gather feedback, or respond to inquiries or complaints. | All categories | Performing our contract with you (or legitimate interest, when not necessary for provision of our Service) |
| To communicate with you regarding possible cooperation | Contacting you to discuss possible forms of cooperation, such as partnership opportunities or service enhancements. | Identifiers | Legitimate interest |
| To process and fulfill your transactions | Managing and fulfilling orders and requests, providing customer support, delivering products, processing payments, providing receipts and confirmations, and processing returns or disputes. | Identifiers; Commercial information; Device and Geolocation data | Performing our contract with you |
| To process and fulfill your orders | Using third-party services for payment processing so you can pay for our Service. We will not store or collect your payment card details ourselves. | Identifiers | Performing our contract with you |
| To provide AI Voice Coaching | Your voice input is captured and transmitted in real-time to third-party AI service providers to generate personalized responses. Profile data may be shared during the session for context. Voice input is not stored after the session ends; session metadata may be retained to improve the Service. | Voice data; Onboarding and product data; Device data | Performing our contract with you. Or consent if the data relates to a special category of personal data in a covered jurisdiction. |
| To research and analyze your use of the Service | Understanding our business, maintaining, improving, innovating, planning, designing, and developing the Service, and statistical analysis to test and improve our offers. | All categories | Legitimate interest (unless it requires consent, e.g., special category data or methods covered by certain e-Privacy regulations) |
| To send our marketing communications | Adding your email to our marketing list (where we have consent or another legal basis) to send information such as special offers. You can unsubscribe via the footer of marketing emails. | Identifiers | Consent or Legitimate interest (in jurisdictions that allow an exception to consent requirements) |
| To personalize our ads | Tailoring ads and showing them at relevant times (e.g., in your Instagram feed). | Onboarding and product data; Internet/network activity; Commercial information; Device and Geolocation data; Advertising IDs; Cookies and similar technologies | Consent or Legitimate interest (unless consent is required, e.g., under certain e-Privacy regulations) |
| To audit ad performance | Counting ad impressions to unique visitors, verifying positioning and quality, and auditing compliance with standards. | Identifiers; Onboarding data; Internet/network activity; Commercial information; Device and Geolocation data; Advertising IDs; Cookies and similar technologies | Consent or Legitimate interest (unless consent is required) |
| To enforce our Terms and to prevent and combat fraud | Defending our legal rights and interests in disputes or claims, responding to legal requests, and establishing, exercising, or defending our legal position. | All categories | Legitimate interest |
| To comply with legal obligations | Complying with tax regulations, accounting standards, and other laws (e.g., calculating and reporting taxes, issuing invoices, responding to lawful requests from authorities, complying with CCPA and GDPR). | All categories | Complying with legal obligation |
In particular, we rely on the following legitimate interests: to communicate with you regarding your use of the Service (encouraging you to use our services and gain the benefits of our plans); to communicate regarding potential collaborations (establishing and maintaining business relationships); to research and investigate your use of the Service (understanding preferences and improving the experience); to send marketing communications (promoting our services in a measured manner, unless you have opted out); to personalize our advertisements (reasonably targeting our ads); to audit ad performance (ensuring accuracy and adherence to standards); to defend our legal rights and interests (protecting ourselves in disputes and complying with laws); and to enforce our terms and prevent fraud and misconduct (exercising legal rights and resolving fraud or unauthorized use).
3. Entities with Whom We Share Personal Data
A. General Categories
We employ partners who use their technology and resources to perform certain services or business functions on our behalf under our instructions. Such collaborations may involve processing your data through the partner's software development kits (SDKs), APIs, cookies, or other technologies, meaning your information is transmitted and processed on our partners' servers for our purposes (although partners typically do not have direct access to specific information).
This type of personal data processing may be considered sharing information with third parties. We have data processing agreements with all such parties to ensure that the data is processed in accordance with our instructions and is limited to the terms of the agreement. Our partners assist in operating, providing, improving, integrating, customizing, supporting, and marketing our services. The types of third parties with whom we share information include the following:
Third-party service providers
We share information with third parties we hire to provide services or perform business functions on our behalf, based on our instructions.
Cloud storage providers
To host personal data and operate and distribute our services, we use Amazon Web Services, a hosting and backend service provided by Amazon.
Product monitoring service providers
To monitor infrastructure and app performance, we use Crashlytics (a monitoring service provided by Google), Firebase Performance Monitoring and Firebase Crash Reporting (Google), Sentry (provided by Functional Software Inc., to detect and resolve app errors and crashes), and Logz.io (provided by Logz.io Ltd., to collect, analyze, and visualize logs).
Data analysis providers
To investigate and analyze how users interact with our app, we use AppsFlyer (advertising performance measurement). We use Amplitude (general analytics) and Google Analytics (web analytics) to understand how customers use our services and measure ad effectiveness. To track and analyze user behavior (e.g., A/B testing of app structure or text), we use Firebase Remote Config, a service provided by Google.
Marketing service providers
We use Meta Custom Audience and Meta Ads Manager to select audiences for our ads on Facebook and Instagram; Google Ads to display and customize ads; Snapchat Advertising Platform and Snapchat Audience Based Match; and Pinterest conversion tracking. We also work with ad networks, ad agencies, and direct publishers. These services may collect information such as your device ID or IP address. You can opt out of interest-based advertising via the Digital Advertising Alliance's Consumer Choice Page or the Network Advertising Initiative's Consumer Opt-Out Page.
Storage of chatbot conversations by OpenAI
Chatbot interactions within our service are stored and processed by OpenAI. These conversation logs may be used for service improvement, enhancing user experience, and troubleshooting technical issues. OpenAI securely stores the collected data and implements appropriate security measures. Users can request to delete their conversation logs at any time, handled according to OpenAI's data deletion policy.
Processing of Voice Coaching sessions by Google
Voice Coaching sessions within our service are processed in real-time by Google's AI services (Gemini). During a session, your voice input and relevant profile context are transmitted to Google's servers to generate real-time responses. Unlike text-based chatbot conversations, voice data is processed in real-time only and is not stored or retained by Google or by us after the session ends. No voice recordings are created, saved, or made available to any party after a session concludes. Session metadata (such as duration and frequency) may be retained by us for service improvement purposes.
Subscription Management and Payment Information Processing
Our service uses RevenueCat to manage subscriptions and process payments. RevenueCat encrypts payment information, and we do not collect, store, or manage any sensitive payment data. Subscription information is used solely to provide better services and will not be sold or shared with third parties without consent.
Health apps
You may allow us to share data with health apps; we will transmit your workout, weight, and dietary energy (caloric intake) information to those health apps.
Law enforcement and other public authorities
We may use and disclose personal data to enforce our terms of service; protect the rights, privacy, safety, or property of us, our affiliates, you, or others; respond to legal processes; and in other cases as required by law.
Third parties involved in acquisitions or mergers
As our business grows, we may buy or sell assets or business products, and customer information may be among the transferred business assets, including during transactions such as a sale, merger, consolidation, or asset sale.
Affiliates
We may share your personal data with partner organizations within our corporate group, who will use the information in accordance with this Privacy Policy.
Service Providers and Third Parties under the CCPA Classification
We may share your personal data with other entities that perform functions on our behalf or support our objectives, classified as service providers (or contractors) or third parties under the California Consumer Privacy Act (CCPA). Not all categories may apply to you, and the scope of personal data usage may vary depending on the services you use.
| Category of Service providers | Purpose of sharing data | Categories of personal data shared |
|---|---|---|
| Cloud storage service providers | To store your personal data and enable provision of our Service | All categories of personal data |
| Product monitoring service providers | To prevent and/or address errors or technical issues | All categories of personal data |
| Communication service providers | To provide our Service, maintain and service your account, provide customer service, and communicate about your use of our Service | Identifiers; Onboarding data; Internet/network activity; Commercial information; Device and Geolocation data; Conversations with the AI Chatbot Coach; Comments provided with your requests |
| Marketing service providers | To send marketing communications and deliver our ads | Identifiers; Advertising IDs; Onboarding data; Internet/network activity; Commercial information |
| Email verification service providers | To verify your information before creating an account | Identifiers |
| Gateway service provider and payment processors | To process and fulfill your transactions | Identifiers; Onboarding data; Commercial information; Device and Geolocation data |
| Processing orders providers (like Shopify) | To process and fulfill your orders | Identifiers; Store purchases data |
| Data analytics providers | To research and analyze your use of the Service and audit ad performance | All categories of personal data |
| AI service providers (e.g., Google Gemini) | To provide real-time AI Voice Coaching sessions | Voice data; Onboarding and product data (contextual profile data shared during sessions) |
Under California law, the categories of third parties to whom the disclosure of personal information may be considered a "sale" include: marketing service providers and data analytics providers.
4. How to Exercise Your Data Privacy Rights
General Data Privacy Rights
You have the following rights to manage your personal data:
- Access / Review / Update / Correction of Personal Data: You may review, modify, or change the personal information you previously provided. To obtain a copy of the data we process, submit a data access request, or use the privacy features generally available in the profile section.
- Deletion of Personal Data: You may request deletion where permitted by law. In some cases we may be required to retain certain data (e.g., payment information) for a specific period for legal reasons; we will complete the rest of the request after fulfilling our legal obligations.
- Understanding the Data Processing Process: You have the right to be informed about the collection and use of your data, including what data is processed, why, who it is shared with, and how long it is retained.
- Objecting to or Restricting the Use of Personal Data: You may request that we stop or restrict use, including Email Marketing (unsubscribe via the link in every email or contact support), Electronic Privacy Settings (influence tracking at a purpose-specific level via the footer, menu, or profile section), and Microphone Access (revoke at any time through your device settings; this prevents Voice Coaching but does not affect other features).
Additional Means Affecting Personalized Ads:
- iOS: Go to "Settings" → "Privacy & Security" → "Advertising" to enable "Limit Ad Tracking." You can also reset your advertising identifier there.
- Android: Open the Google Settings app, tap "Ads," and enable "Opt-out of interest-based ads." You can also reset the advertising identifier there.
For more details on ad choices across devices, see: Network Advertising Initiative (optout.networkadvertising.org), Digital Advertising Alliance (optout.aboutads.info), Digital Advertising Alliance Canada (youradchoices.ca/choices), Digital Advertising Alliance EU (youronlinechoices.com), and the DAA AppChoices Page (aboutads.info/appchoices).
- Right to Complain to a Supervisory Authority: Please contact us directly to resolve any concerns. You also have the right to lodge a complaint with the relevant data protection authority.
- Right to Data Portability: You can request a copy of your personal data in a machine-readable format (such as a .json file).
Exercising Your Rights
To exercise any of your rights, please send a request to soundgym@soundgym.io or use the privacy features available in our products.
Verification: To process your request, we must verify it. This may include verifying your name, age, email, subscription purchase date, last activity date, account creation date, or other usage data that reasonably confirms account ownership. We make every effort to use the minimum necessary information (e.g., for some requests, we will send you a verification code or link).
Authorized Agents: You may designate an authorized agent to exercise your rights on your behalf. If appropriate power of attorney has not been provided, we will contact you directly to verify the agent's authority. Authorized agents must verify both their identity and the consumer's identity.
California Privacy Rights
This section explains additional rights available to California residents under the CCPA and the California "Shine the Light" law, and therefore applies only to California residents. In addition to the rights listed above, the CCPA grants you:
- Right to know what personal information has been sold or shared and to whom, including the categories of personal information collected, the categories sold or shared and to which third parties, and the categories disclosed for business purposes.
- Right to opt out of the sale or sharing of personal information. In certain circumstances, sharing with partners for targeted advertising or analytics may be considered a "sale," "sharing," or "targeted advertising" under California law.
- Right to not be discriminated against for exercising your rights under CPRA.
Under the Shine the Light law, California residents may inquire once a year about what personal information has been shared with third parties for direct marketing purposes. To request this, email soundgym@soundgym.io with the subject line "Request for California Shine the Light Privacy Information" and include your state of residence and email address.
5. International Data Transfers
We may transfer personal data to countries outside the one where the data was originally collected to provide services as stated in our Terms of Service and for the purposes described in this Privacy Policy. If such countries do not have the same data protection laws as the country where you initially provided the information, we will apply appropriate safeguards such as standard data protection clauses adopted by the EDPB.
6. Changes to This Privacy Policy
We may modify this Privacy Policy from time to time. If we make significant changes, you will be notified through our service or other means, and you will have the opportunity to review the revised Privacy Policy. Continuing to access or use the service after such changes take effect will indicate your acceptance of the revised Privacy Policy.
7. Data Retention
We retain your data for as long as reasonably necessary to fulfill the purposes outlined in this Privacy Policy and our Terms of Service (including providing the service). This generally includes the period during which you maintain an account. We may also retain and use your personal information as necessary to comply with legal obligations, resolve disputes, and enforce contracts. With respect to Voice Coaching, voice input data is processed in real-time and is not retained after the session ends; voice coaching session metadata (such as duration and frequency) is retained for the same period as other service usage data.
8. Contact
If you have any questions regarding this Privacy Policy, prior versions, or our information practices, or questions about your account or personal data, please contact us at soundgym@soundgym.io.
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