Privacy Policy

01 Information We Collect

Information You Provide

• Account information: email address, display name, username, and authentication credentials. If you sign in with a third-party provider (e.g., Google or Apple), we receive the identifiers that provider shares with us (typically an email address and a name/display name) from that provider. If you sign in with Google, Google also shares the address of your Google profile photo. Our authentication provider keeps it with your sign-in record, and we do not use it as your profile image. If you use Sign in with Apple, we also keep the sign-in token Apple issues to us, solely so that we can revoke it when you delete your account. We record the version of the Terms of Service and Privacy Policy you accepted and when you accepted it, a dated record of each time you allowed or stopped body metrics or nutrition data collection (your Fitness data answer stays on your device), and your account settings (preferred units, notification preferences, and whether nutrition tracking is turned on).
• Profile information: experience level, gender, body weight and your weigh-in history, height, profile image, and in-app appearance choices (such as your figure’s hair color and skin tone). Your profile image is either a photo you pick or one of the App’s portrait images. If you pick a photo, we access only that photo, and it is reduced in size on your device before upload; a portrait is uploaded as a copy marked with the portrait’s name. Experience level is required to set up your training; every other profile field is voluntary.
• Workout data: exercises performed, sets, reps, weights, duration, personal records, workout history, program enrollment, scheduled training days, exercises you mark as favorites, any workout notes, effort (RPE) ratings, or mood ratings you add, and the custom exercises, workout templates, and programs you build.
• Nutrition data: foods and drinks you log, including the portion, quantity, meal, and the date and time of each entry; the calorie, macronutrient, fiber, sugar, and sodium values recorded with it; any custom foods and saved meals you create; foods you mark as favorites; and the calorie and macronutrient goals, goal weight, activity level, a typical daily step count you choose from four bands, and maintenance-calorie estimate you save. Nutrition tracking is voluntary and can be turned off at any time in Settings. The age you enter in the goal calculator is used on your device to calculate your target and is not stored.
• Social data: friend connections, workout challenges (including the set list of a completed workout you send as a challenge), programs and templates you share and receive, leaderboard participation, reactions, comments, cheers you send to friends, and any reports or blocks you submit.
• Camera (barcode scanning): if you use the barcode scanner, the camera is used only to read the barcode, and that processing happens on your device. Camera frames are never recorded, stored, or sent to our servers; a successful scan produces only the product’s barcode number, which we use to look up the food in the catalog. iOS asks your permission before the App can use the camera, and you can revoke it at any time in your device settings.
• Purchase data: purchases are made through Apple or Google, and we never receive your payment card details. Subscriptions and in-app purchases are managed for us by a subscription-management provider, which receives your account identifier and basic device information (such as device type and operating system version) when you sign in and, if you buy something, the purchase details Apple or Google share with it, such as the product, the price, and the renewal or expiration date. We store your entitlement status (for example, which plan is active and when it expires) so we can provide what you paid for.
• Referral information: if you join with a friend’s invite code, we store which account invited yours, when you applied the code, and when the reward was set and granted, so that we can give both accounts the referral reward. If you open an invite link before you sign in, the code waits on your device until you do. Your own invite code is kept with your account. The inviting member is not told your name, email address, or any of your data.
• Support communications: information you provide when you contact us (for example, your email address and the contents of your message).

Information Collected Automatically

• Device identifiers and push notification tokens. Push tokens are transmitted to our notification delivery provider, which forwards notifications to the platform notification service on your device. The text of a notification (for example, a friend’s display name and what they did) passes through that provider, which does not keep it after delivery; a copy of each in-app notification is kept in your notifications inbox as part of your account data. We try to remove your push token when you sign out, and we delete any token that has not checked in for 30 days, which also clears a token left behind after you uninstall the App or revoke notification permission.
• JavaScript error reports, including sanitized error categories, stack traces, and app build metadata. Native crash reporting and performance/session tracking are disabled. These reports are not linked to your account and do not include your name, email, or workout content. They are optional: the Crash reports switch in Settings → Privacy turns them off, and the same choice is offered during onboarding, on the Training step.
• Your device’s time zone, sent with requests so that workout and food-log dates, streaks, and daily totals are computed in your local time. It is not stored.
• Search and lookup requests. Food searches, barcode lookups, and friend searches are sent to our servers to return results. We do not keep the words you typed or the barcode you scanned. We used to keep the words of a food search that returned no results, and the barcode number of a product that was not in our catalog, for up to 90 days so that we could add the missing food; we stopped doing that, and we now record only that a search returned nothing or that a scan found no match. While Usage analytics is on, we also record where a food you picked sat in the results (first to tenth, or lower), what kind of result it was (one of the foods we curate, a general food, a branded product, or one of your favorites, recent foods or own foods), and whether a spelling correction found it. That record holds no food name and no words you typed, and is deleted after 90 days. Records of that kind collected before we stopped are deleted on the same 90-day schedule.
• Usage and interaction data: which features you open and use, and in-app activity such as starting and completing a workout, logging food, creating or enrolling in a program, reacting to or commenting on a friend’s activity, opening a calculator, and whether a food search returned results or a scanned barcode matched our catalog. Each record holds counts, short labels, or the internal record numbers of your own programs and templates: it carries no food name, no words you typed, and no barcode. It also carries how long a workout ran and how many sets and exercises it held. This is tied to your account so we can measure retention and improve the App, kept for no more than 14 months, and never sold. We collect none of it unless you ask us to: the Usage analytics switch in Settings → Privacy is off until you turn it on, that switch is both how you turn this collection on and how you withdraw it, and it is also offered during onboarding, on the Training step. Your Usage analytics choice is kept on this device for your signed-in account; a previous account or an older device-wide permission does not grant permission for another account, and signing out clears the grant. Turning it off stops the collection and discards anything recorded on your device that has not reached us yet; it does not delete records we already hold, which you can obtain with Export my data and remove with Delete account.
• Workout measurements inside those usage records. The total weight you moved in a completed workout, and the exercise, type, and value of a personal record, are included only if you allow it. If you have turned Usage analytics on, we ask once after your first workout. Either way, the Fitness data control in Settings → Privacy shows and changes your answer; it reads Not allowed until you allow it, and your answer is saved on this device for your account before an allowance takes effect. Your workout is saved whatever you answer: this control is only about using its numbers to improve the App.
• IP address and request logs. When the App communicates with our servers, our hosting, crash-reporting, update, email, and notification providers see your IP address and record standard request details in security and diagnostic logs that are kept for a short period.
• Site data (when you visit the Site): standard web log data such as IP address, browser type, device type, pages viewed, and the date/time of access.
• Cookies. The Site does not set cookies and does not use analytics or tracking. If that changes, we will update this policy and provide any notice the law requires before doing so.

On your device. The App keeps a copy of your data on your device so it works offline, and on iOS it shares your profile image and headline stats with the home-screen widget and Live Activity through a container on your device. Nothing in that container is sent anywhere.

What we do not collect. We do not collect your location, contacts, or any photos other than a profile image you choose. We do not record audio. We do not read data from Apple Health, Google Fit, or any other app. We do not use advertising or tracking SDKs.

02 How We Use Your Information

We use the information we collect to:

• Provide, operate, and personalize the App and Site
• Track your workouts, progress, and achievements
• Record the food you log and calculate the calorie and macronutrient targets you ask us to calculate
• Provide the paid features you purchase and keep your subscription status current
• Deliver push notifications you have opted into (e.g., friend requests, challenges, template shares, cheers from friends, and reactions or comments on your activity)
• Enable social features such as leaderboards, challenges, and friend activity
• Send you service messages about your account, including notice of material changes to these documents
• Review reports, enforce our Terms of Service, and keep the community safe
• Diagnose technical issues and improve App stability
• Comply with legal obligations
• Protect the App and Site, including detecting, preventing, and responding to fraud, abuse, and security incidents

Legal bases. The App is offered in the United States. If we make it available in a jurisdiction that grants additional data-subject rights or requires disclosure of specific legal bases (for example, the EEA under the GDPR or the UK under the UK GDPR), we will update this policy and, where those laws require explicit consent before processing special category data such as body metrics or the food you log, we will obtain that consent before the processing begins. Today, you allow body metrics before we first collect a weigh-in or your height, and nutrition data before we first save a food log or other nutrition entry, each in a consent step, and we record on your account the date and time you agreed. Where we rely on your consent, you may withdraw it at any time.

Artificial intelligence and model training. We do not use your personal information to train large language models or any other artificial intelligence model, and we do not disclose it to anyone else for that purpose. The App has no artificial intelligence feature, and the service providers described in Section 4 are contractually limited to processing your information on our instructions, which do not include training their models. If this ever changes, we will update this policy and obtain any consent the law requires before the change takes effect.

03 Sale of Personal Information

We do not sell, rent, or trade your personal information to third parties for monetary or other valuable consideration. We do not use your personal information for cross-context behavioral advertising, and we do not “share” personal information for that purpose as those terms are defined under the CCPA/CPRA and analogous state privacy laws. We have never sold personal information, and we have no plans to do so. If our practices change, we will update this policy and provide any opt-out mechanisms required by law before the change takes effect.

04 Third-Party Service Providers

We share data with third-party service providers that process data solely on our behalf, including providers of:

• Cloud hosting, database, and authentication
• Push notification delivery and over-the-air app updates
• Crash and error reporting
• Transactional email delivery, which sends your sign-in codes and account notices, and alerts our team when content is reported (the alert carries the report’s reference, the kind of content, the reason category and the time, never the reported content itself)
• Purchase and subscription management
• Sign-in authentication (Apple and Google)

Location of processing. The App is offered in the United States, and our providers may store and process your information in the United States and other countries where they operate. If we make the App available in a jurisdiction that requires transfer safeguards (for example, the European Commission’s Standard Contractual Clauses or the UK International Data Transfer Addendum), we will put those safeguards in place before that processing begins.

05 Disclosure of Your Information

We may share your information only in the following circumstances:

• Service Providers. As described in Section 4, to operate and maintain the App.
• Other Users. While Findable by username is on in Settings → Privacy, any signed-in user can find you by username or display name and see your display name, username, profile image, title, and equipped cosmetics, and can open a profile card that shows the same. When you turn Findable by username off, only the friends you already have can find your account in search, and we refuse a friend request from anyone else. Someone with a pending friend request to or from you can still open that card. If you send someone a friend request, they can view your profile statistics, experience level and earned achievements while deciding. If you accept a friend request, that friend can also see your workout statistics, current streak, rank, level and XP, experience level, earned achievements and the dates you earned them, active program, titles and cosmetics, and your recent workouts: the workout name, duration, and total volume, and for any personal record the exercise and the weight, reps, duration, or pace of the record set (but not your other sets, notes, effort ratings, or mood ratings). The activity feed also shows your accepted friends when you join, earn an achievement, reach a new realm or stage, reach a streak or level milestone, finish a program or a challenge, or choose a patron. Leaderboards rank you only among your accepted friends; there is no public leaderboard. Comments you leave on a friend’s activity are visible to everyone who can see that activity, including that friend’s other friends. If you send a friend a workout challenge, that friend receives the full list of sets from that workout, with weights and reps, so they can repeat it; this is the only time your set list leaves your account. If you share a program or template with a friend, they receive its full content. If you share a program by link, anyone who has the link and is signed in to the App can view and copy it. While a workout is in progress, your accepted friends can also see that you are currently training and how long ago you started. Friends can send you a brief encouragement notification during a workout. If you have Pro and turn on the Pro emblem, other users who see your profile image on your profile, in the activity feed or on a leaderboard also see a small bolt on it that shows you have Pro. The emblem is off until you turn it on, and you can turn it off at any time in Settings. Your nutrition data and body weight are never shown to other users. Profile images are stored on a publicly accessible content server. Because profile images may be hosted at a publicly accessible URL, anyone with the URL may be able to view the image. If you prefer, you can choose not to upload a profile image.
• Sharing you start. If you choose Share on a workout, record, achievement or other card in the App, the App makes an image on your device and hands it to the iOS share sheet. We do not upload that image; whoever you send it to, or the service you post it on, receives it under their own terms.
• Legal Requirements. We may disclose information if required by law, court order, or governmental request, or to protect our rights, your safety, or the safety of others.
• Business Transfers. In the event of a merger, acquisition, or sale of assets, your information may be transferred. We will notify you of any such change.

06 Health, Body, and Nutrition Data

Body weight, height, and the nutrition information you log are collected to support workout tracking, nutrition tracking, and progress visualization. We do not access Apple Health, Google Fit, or any third-party health platform. We do not use health, fitness, or nutrition data for advertising, marketing, or data mining, and we do not collect location data or use geofencing. No body metrics or nutrition data are collected when you sign up.

Body metrics are opt-in. Before the App first collects a weigh-in or your height, a consent step asks you to allow it and records on your account the date and time you agreed, and we keep a dated record of each time you allowed or stopped body metrics or nutrition data collection, for as long as your account exists; both the current grant and that history are in your data export. If you decline, we collect neither, and nothing you have already logged is deleted. Where the GDPR, UK GDPR, or comparable law requires your explicit, opt-in consent before we process your body metrics as special category or sensitive personal data, we obtain it.

Nutrition data is opt-in too. Before the App first saves a food log, a calorie goal, a saved meal, a custom food, or a starred food, a consent step asks you to allow it and records on your account the date and time you agreed. If you decline, nothing is saved. The Nutrition data control in Settings → Privacy reads Not allowed until you allow it. Set Body metrics data or Nutrition data to Not allowed at any time and we stop collecting that category; nothing you have already logged is deleted. You can turn nutrition tracking off at any time in Settings, which hides the feature without deleting anything you have logged. You can also remove what we hold by deleting the entries in the App or by deleting your account; your nutrition data is included in data export and account deletion whether the feature is on or off.

Our Consumer Health Data Privacy Policy (also available at https://fulminata.app/health-data) describes how we handle consumer health data, including the disclosures and rights provided under Washington, Nevada, and Connecticut law.

07 Data Security

We implement reasonable administrative, technical, and physical safeguards to protect your information. Data is transmitted using industry-standard encryption (TLS/HTTPS). Authentication credentials are stored in secure on-device storage. Access to your data is restricted by role-based security policies. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security. If we determine that a security incident has resulted in the unauthorized acquisition of, access to, or disclosure of your personal information, we will notify you and, where required, applicable regulators within the timeframes prescribed by applicable law. Email to the address associated with your account is our primary method of communicating with you, including for any such notice.

08 Data Retention and Deletion

We retain your information for as long as your account is active or as needed to provide you with the App, and we delete some of it sooner on an automatic schedule: any words of a failed food search or barcode number of a catalog miss still held from before we stopped keeping them, within 90 days; usage and interaction records after 14 months; read in-app notifications 90 days after they were sent, and unread ones after 12 months; and moderation reports 24 months after they are filed, or sooner if the account that filed them is deleted. We keep the record of your body metrics and nutrition collection choices for as long as your account exists. If Apple does not accept the revocation of your Sign in with Apple token when you delete your account, we do not delete the account: we keep it so you can retry, and we keep a record of the failed attempt (your account identifier and Apple’s response) for up to 24 months. Crash reports are kept by our crash-reporting provider for up to 90 days, and server request logs for a short period. Support emails are kept as long as needed to resolve your request and for our records. We need not delete information to the extent retention is required by law, regulation, or court order, or requested by a government agency. You may export your data at any time from Settings → Data & Account → Export my data; the export includes your profile, workout, nutrition, social, and settings data. Your subscription status is deleted with your account; Apple or Google and our subscription-management provider keep their own transaction records under their policies, and we do not hold your payment details at any point.

You may permanently delete your account and the data we hold for it, subject to the exceptions in this section, from Settings → Data & Account → Delete account. If you no longer have the App installed, you can request deletion at https://fulminata.app/delete-account or by emailing support@strudelacademy.com from the email address on your account. We will begin processing deletion promptly after you submit the request. Deletion is processed as soon as reasonably practicable and is irreversible, except where retention is required by applicable law. We may retain limited information in backups for a period of time and will delete or de-identify it when backups are rotated or as required by law. We may retain de-identified or aggregated data that cannot reasonably be used to identify you. A program you built that other users adopted stays available to them with your name removed.

09 Your Rights and Choices

Depending on your jurisdiction, you may have the right to:

• Access and receive a copy of your personal information
• Correct inaccurate personal information
• Delete your personal information
• Opt out of push notifications at any time in Settings → Notifications, or via your device settings
• Decide whether we collect usage analytics at all, with the Usage analytics switch in Settings → Privacy; it is off until you turn it on, and turning it back off stops the collection and discards anything still waiting on your device, while anything we already hold is covered by Export my data and Delete account
• Decide whether the measurements in a completed workout are used to improve the App, with the Fitness data control in Settings → Privacy; it reads Not allowed until you allow it, and your workouts are saved either way
• Turn off crash reports at any time with the Crash reports switch in Settings → Privacy; turning it off stops them straight away, and turning it back on takes effect the next time you open the App
• Control whether other users can find you, with the Findable by username switch in Settings → Privacy; with it off, only the friends you already have can find your account in search, and we refuse a friend request from anyone else
• Stop our collection of body metrics or nutrition data at any time with the Body metrics data and Nutrition data controls in Settings → Privacy; each is collected only after you allow it, and setting either to Not allowed stops further collection and deletes nothing

California Residents: Under the CCPA/CPRA, you have the right to know what personal information we collect, request deletion, request correction, and opt out of the sale of personal information (we do not sell). We will not discriminate against you for exercising your rights. Some of the information we collect, such as body metrics and the food you log, may be considered sensitive personal information under the CPRA. We use and disclose it only to provide the App and for the other purposes described in this policy, and never to infer characteristics about you. Because we do not use or disclose sensitive personal information beyond the purposes the CPRA permits, we are not required to offer a “Limit the Use of My Sensitive Personal Information” option. We do not sell or share personal information, so a Global Privacy Control signal has nothing to opt out of, and we do not respond to browser Do Not Track signals; the Site sets no cookies and runs no analytics. If you use an authorized agent to submit a request on your behalf, we may require proof of the agent’s authorization and may still ask you to verify your identity directly.

Other U.S. State Residents: If you reside in a state with a comprehensive privacy law in effect (currently including Virginia, Colorado, Connecticut, Utah, Texas, Florida, Oregon, Montana, Iowa, Delaware, New Hampshire, New Jersey, Tennessee, Indiana, Minnesota, Maryland, Rhode Island, Kentucky, and Nebraska), you may have rights to access, correct, or delete your personal information, to opt out of the sale of personal information, targeted advertising, or certain profiling (we do not engage in any of these), and to appeal a denied request. To exercise a right, contact us at the email address below.

Washington, Nevada, and Connecticut Residents: Our Consumer Health Data Privacy Policy describes the additional rights that apply to consumer health data, including how to appeal a decision.

Nevada Residents: Our designated request address, for a verified request under Chapter 603A of the Nevada Revised Statutes, is support@strudelacademy.com. Send your request from the email address on your account and we will respond within 60 days, or tell you why we need up to 30 days more. We do not sell personal information, so there is nothing to opt out of; the address is available to you either way.

You can exercise most of these rights directly within the App. For additional requests, contact us at the email address below. To help protect your privacy and security, we may need to verify your identity before processing certain requests (for example, by requiring that you send the request from the email address associated with your account and/or by confirming certain account details). If we deny your request, you may appeal our decision by replying to our denial message or emailing us at support@strudelacademy.com with the subject line “Privacy Appeal.” If your appeal is denied, you may submit a complaint to your state attorney general.

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. To request to review, update, or delete your personal information, please contact us at the email below.

10 Children’s Privacy

The App is intended only for adults age 18 and older. Before access to workout, nutrition, and social features, the App checks eligibility using Apple’s age-range service where supported; where the service permits declining to share or is unavailable on an older operating system, the App asks for an adult-age confirmation. A self-confirmation is only accepted where Apple’s age-range service is unavailable on your operating system or you have declined to share your age range; it is not accepted where Apple returns an underage or inconclusive response, and a failed or inconclusive check does not grant access. The App processes Apple’s age response on your device and does not send the age range to our servers. Your self-confirmation, adult or underage, is stored only on your device, separately from your account and health-data consent, and the App asks again when a different account signs in on that device. You can correct a mistaken answer or check again after turning 18, but this does not override an underage response from Apple. The App re-queries Apple’s service on each launch, before it reads a stored self-confirmation, so a user whose response later returns as 18 or older will gain access automatically. If you believe an age-range response is incorrect, you can request review by emailing support@strudelacademy.com from the address on your account. Apple’s response controls and the App cannot override it; once Apple corrects it, the App gives you access the next time it checks. A separate account-access path allows existing users to request a data export or delete their account without access to workout, nutrition, or social features. We do not knowingly permit minors to use the App. If you believe someone under 18 has provided us with personal information, contact us at support@strudelacademy.com so we can investigate and delete it.

11 Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Effective” date at the top of this page. For material changes, we will notify you in the App, and by email where the law requires it, before the change takes effect; when we ask you to accept the updated policy in the App, we keep a record of the version you accepted and when. Your continued use of the App after any changes constitutes your acceptance of the updated policy.

12 Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the State of Wisconsin, United States, without regard to its conflict-of-law principles.

13 Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us at: