Privacy Policy

Last updated: 15 June 2026

This Privacy Policy explains how smaartcoach (“smaartcoach”, “we”, “us”) collects, uses, shares and protects your personal data when you use our AI fitness coaching service delivered through WhatsApp (the “Service”). We are committed to handling your data in line with the EU General Data Protection Regulation (GDPR) and Brazil’s Lei Geral de Proteção de Dados (LGPD).

We are the data controller for the personal data processed through the Service. For any privacy question or to exercise your rights, contact us at privacy@smaartcoach.com.

1. Data we collect

Information you give us

Account & contact: your WhatsApp phone number and the WhatsApp profile name shown to us.
Fitness profile (health-related): your goal, sex, age, height, weight, training days, where you train and available equipment.
Activity you log: meals (and the calorie/macro estimates we generate), workouts completed, weight entries, streaks and progress.
Messages you send: the text, voice notes and photos you send in the chat so the Service can respond.
Payment information: your subscription status and billing identifiers. Card/payment details are collected and processed directly by our payment processor; we do not see or store your full card number.

Information collected automatically

Technical and usage data needed to deliver and secure the Service (e.g., message timestamps, delivery status, coarse interaction logs).

Photos and voice notes. When you send a food photo, we retrieve it from WhatsApp and pass it to our AI provider to estimate its contents in memory only. We do not store your photos on our servers. Voice notes are transcribed to text to understand your request; we keep the resulting text where needed to provide the Service and do not retain the original audio.

2. How we use your data

To provide the Service: analyze meals, generate personalized workouts and nutrition targets, answer your questions, track progress and streaks.
To set up and manage your subscription and process payments.
To send you service messages (e.g., reminders, plan updates) consistent with your settings and WhatsApp’s policies.
To maintain security, prevent abuse, debug and improve the Service.
To comply with legal obligations.

3. Legal bases for processing

Under GDPR/LGPD we rely on: performance of a contract (to deliver the Service you request); your consent, including your explicit consent to process health-related data and to receive messages, which you may withdraw at any time; our legitimate interests (securing and improving the Service); and compliance with legal obligations (e.g., tax/accounting for payments).

4. How we share data

We do not sell your personal data. We share data only with trusted service providers that help us operate the Service, under appropriate data-processing agreements. These providers fall into the following categories:

Messaging providers, to deliver and receive your chat messages.
AI service providers, to analyze your meals, generate coaching replies and transcribe voice notes.
Payment processors, to manage your subscription and handle billing securely.
Cloud hosting and database providers, to run the Service and store your account and activity data.
Content delivery providers, to host and serve exercise videos and website assets.

We may also disclose data if required by law, to enforce our Terms, or to protect the rights, safety and property of our users or others.

5. International transfers

Some of these providers process data in countries outside your own (including the United States and the European Union). Where data is transferred internationally, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses and equivalent mechanisms under the LGPD.

6. Data retention

We keep your account and fitness data for as long as your account is active. If you stop using the Service or ask us to delete your data, we delete or anonymize it (see “Your rights” and our Data Deletion page), except where we must retain limited records to meet legal, tax or accounting obligations or to resolve disputes.

7. Your rights

Subject to applicable law, you have the right to: access your data; correct inaccurate data; delete your data; restrict or object to processing; data portability; and withdraw consent at any time (without affecting prior processing). You also have the right to lodge a complaint with your data protection authority (in Brazil, the ANPD; in the EU, your local authority).

To exercise any right, email privacy@smaartcoach.com or follow the steps on our Data Deletion page. You can also withdraw messaging consent at any time by replying STOP in the chat.

8. Security

We use industry-standard measures to protect your data, including encryption in transit, access controls and reputable infrastructure providers. No method of transmission or storage is 100% secure, but we work to protect your information and continually improve our safeguards.

9. Children

The Service is not directed to children. You must be at least 18 years old (or the age of majority in your jurisdiction) to subscribe. We do not knowingly collect data from children; if you believe a child has provided us data, contact us and we will delete it.

10. Changes to this policy

We may update this Policy from time to time. We will post the updated version here and change the “Last updated” date; material changes may also be notified in the chat.

11. Contact

Questions or requests: privacy@smaartcoach.com.