PRIVACY POLICY ================================================================================ This Privacy Policy describes how your privacy is protected when you use our applications, websites, and related services (collectively, the "App"). PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE APP, YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS DESCRIBED HEREIN AND ALL TERMS INCORPORATED BY REFERENCE. IF YOU DO NOT AGREE TO ALL OF THE TERMS, YOU MAY NOT USE THE APP. If you live in the European Union, you confirm that you have reached the legally required minimum age in your country for the processing of your personal data and that you have the approval of someone with parental authority. SCOPE ===== This Privacy Policy applies to information (including personal information) collected through the App. For the purpose of this Privacy Policy, "personal information" means information that identifies you personally, either alone or in combination with other information. Personal information does not include technical, device, or usage information that cannot be used to identify you, nor does it include "aggregate" data where individual identities are removed. We may freely collect, use, and share aggregate and non-personal information. DATA CONTROLLER =============== The App provider acts as the data controller for the collection and processing of your personal data. In case of in-app purchases, responsibility may be shared with the payment service provider. For example, the payment provider (and not the App provider) is responsible for processing data relating to financial transactions and invoicing. INFORMATION WE COLLECT ====================== We collect and process your data only with your explicit consent, and we retain proof of such consent in compliance with Meta's Platform Terms. We collect information in the following ways: Personal information you provide: --------------------------------- When you register, create an account, contact support, or use our services, we may collect your name, email address, username, social media information, and other data you voluntarily provide. User Content: ------------- Information you share or submit via the App, such as photos, videos, audio, written comments, graphics, and interactive features. Information about others: ------------------------- With your consent, we may access your contacts to share content or invite others. If you upload content containing information about others, such as names or images, that information may also be collected. Content metadata: ----------------- Content you share may include metadata such as hashtags, comments, location data (geotags), or other tagging information. Device and technical information: ---------------------------------- We may collect device identifiers (Device ID), mobile carrier, device type, manufacturer, phone number, and location data (GPS coordinates or similar, depending on your settings). Health and Fitness Information: ------------------------------- Fyro is a fitness and wellness app, and to generate personalized workout and nutrition plans and to track your progress, we collect and process health and fitness information that you provide or that the app generates. This includes: - Physical characteristics: gender, year of birth (age), height, current weight, and target weight, and a calculated body-mass index (BMI). - Body measurements and composition: body-fat percentage; measurements of body areas (e.g., chest, waist, hip, arm, thigh, calf); and progress photos you choose to add. - Fitness profile: fitness/experience level, daily activity level, target body areas, available equipment, preferred workout days and durations, and your fitness goals and motivations. - Physical limitations: injuries or areas of discomfort you report (e.g., knee, lower back, shoulder, wrist, ankle) so we can adapt your plan. - Workout and meditation activity: completed workouts and exercises, session start and completion times, duration, and calories burned; meditation sessions and durations. - Nutrition and hydration: meals you log (including food names, photos, ingredients, serving sizes, calories, and macro- and micro-nutrients) and water intake. - Wellbeing information: mood, emotions, stress level, sleep quality, and any notes you add. - Daily goals: your calorie, hydration, step, and meditation targets. Apple Health and Google Health Connect. With your explicit permission, the app integrates with Apple Health (on iOS) and Google Health Connect (on Android). When you grant access, we may: - read step count, active energy/calories burned, workout records, and body weight from Apple Health or Health Connect; and - write workout sessions, calories burned, and weight entries back to Apple Health or Health Connect. You can grant or revoke this access at any time in your device's Apple Health or Health Connect settings, or in your system settings. Revoking access does not delete data already imported, which you can manage as described in "Your Rights." HOW WE USE YOUR INFORMATION =========================== We use personal information to: - Communicate with you and process requests/transactions - Provide updates, improvements, and new features - Customize services and products for you - Develop, analyze, and improve products and services - Detect abnormal use, fraud, or security issues - Take appropriate security measures - Comply with legal obligations and requests from authorities Legal Basis (for EU Users) --------------------------- Contract necessity: Providing services you request Legitimate interest: Product development, analytics, fraud prevention Legal obligations: Security, compliance, and data protection laws We use your health and fitness information to: - generate and adjust your personalized workout and nutrition plans; - calculate goals (such as calorie and hydration targets) and track your progress over time; - display statistics, history, and achievements; and - sync activity and body metrics with Apple Health or Health Connect when you enable that feature. We process this information to provide the service you request and, where required by law, on the basis of your consent. SHARING INFORMATION =================== We may share your information with: - Subsidiaries, affiliates, and companies under common ownership - Third-party vendors and service providers (e.g., hosting, analytics, payments) - Advertising partners (subject to your settings) - Business partners in joint offerings (e.g., co-sponsored promotions) - At your request (e.g., sharing content with friends) - The public (if you make content public or interact with us on social media) - In connection with business transactions (e.g., merger, acquisition, bankruptcy) - As required by law, regulation, or to protect our rights, users, or the public We may also share data in aggregated or anonymized form. Health and fitness data. We do not sell your health and fitness information, and we do not use it for personalized advertising. We share it only with service providers that host and operate the app on our behalf (such as our backend and cloud-storage providers) and only as needed to provide the service. Data obtained from Google Health Connect is used solely to provide in-app features and is never transferred to or used by third parties for advertising or marketing, sold to any third party, or used to determine creditworthiness or for lending purposes. Our use of information received from Health Connect adheres to the Google Play Health Connect requirements, including the Limited Use requirements. DIGITAL ADVERTISING =================== We may work with advertising providers who use information such as device IDs, demographics, and usage patterns to serve relevant ads. You can manage your preferences in the App's settings. DATA TRANSFERS ============== If required for service delivery, we may transfer data to the United States or other countries, using appropriate legal safeguards (such as the EU–US Data Privacy Framework or equivalent). DATA RETENTION ============== We retain personal data as long as necessary for the purposes described above, unless a longer retention period is required by law or justified by legitimate interests (such as compliance or archiving). You can delete logged health and fitness entries within the app. When you delete your account, the associated health and fitness data is deleted from our systems, subject to any retention required by law. YOUR RIGHTS =========== All users can request data deletion at any time through the in-app settings or by emailing [email protected]. We also honor deletion requests received via Meta's Data Deletion Callback. Depending on your location (e.g., EU, California), you may have rights to: - Access your personal data - Correct inaccurate or outdated data - Delete your data when no longer needed - Restrict or object to processing - Withdraw consent (where applicable) - Request data portability To exercise these rights, please use the support contact information provided within the App. For security reasons, we may require confirmation via your registered email address. LINKS TO THIRD-PARTY SITES =========================== Our Apps may contain links to third-party websites. These websites have their own privacy policies, and we are not responsible for them. Please review their policies before sharing information. CALIFORNIA RESIDENTS ==================== If you are a California resident, you may request details about personal information shared with third parties for marketing purposes or request removal of publicly posted content (per California Civil Code §§ 1798.83 and 22581). To make such a request, please use the support contact information provided in the App. CHANGES TO THIS POLICY ====================== We may update this Privacy Policy periodically. Any material changes will be posted in the App or on our website, with an updated "Last Modified" date. We encourage you to review the policy regularly. -------------------------------------------------------------------------------- Last Revision Date: This Policy was last revised on, and effective as of 11 June 2026.