Privacy Policy

Draft. This document has not been legally reviewed yet and may change before launch. Last updated: to be set at launch.

This is a translation provided for convenience. In case of any discrepancy, the Portuguese version prevails.

1. Scope

This Policy explains how ARCH collects, uses, stores, analyzes, shares, protects and deletes personal data when you use the app, its nutrition, training, body progress, artificial intelligence, health and fitness integration, social, subscription features and any other features made available now or in the future.

It applies to users located in Brazil and in other countries, including users in the European Union, the United Kingdom and the United States, subject to the mandatory rules of the law applicable where the user is located.

2. Who is responsible for the data

Controller: ASSINCRONO LTDA (trade name: ASSINCRONO)
CNPJ (Brazilian company registration number): 69.619.850/0001-79
Address: Curitiba/PR, Brazil
Data Protection Officer (DPO): contact by e-mail at privacidade@assincrono.com

3. Minimum age

ARCH is intended for people aged 16 or older. Between 16 and 18, use requires authorization from parents or legal guardians.

When creating an account, you declare that you are at least 16 years old. ARCH does not request an identity document solely to verify age.

For those who state they are under 18, the profile starts as private and automatic workout sharing is restricted to followers. These choices can be changed later in Settings. Adolescents’ data is processed in their best interest, in accordance with article 14 of the LGPD (Brazilian General Data Protection Law).

If we identify that an account belongs to a person under 16, we may restrict access, delete the account and erase the data in accordance with applicable law.

4. Data we may collect

We may collect:

registration and login data, such as e-mail, name, account identifier, profile photo and data received from Apple or Google;
setup data, such as sex or gender, age, height, weight, goal, activity level, diet type, food preferences, allergies and intolerances;
nutrition data, such as foods, meals, calories, protein, carbohydrates, fats, water, goals and history;
workout data, such as exercises, sets, repetitions, loads, duration, frequency, performance and history;
body data, such as weight, measurements, body fat percentage and progress photos;
health and fitness data, when authorized, such as steps, calories, distance, exercise sessions and heart rate;
location data, precise or approximate, as described in this Policy;
photos taken or chosen by the user for posts, profile or body progress;
data on posts, comments, likes, followers, groups, rankings, reports and blocks;
technical data, such as device model, operating system, app version, error logs, security events and technical identifiers;
usage log for support: screens opened, actions taken in the app, notices displayed and errors, with date and time, kept for up to 10 days and then automatically deleted, used only to understand and solve reported problems. This log does not include what you type;
usage statistics: actions taken in the app (for example, creating a workout, generating a diet or connecting Apple Health), with date and time, app version, operating system version and device model, used to understand how the app is used and improve it; they are kept while the account exists and are deleted together with it;
push notification token and communication preferences;
subscription, purchase, trial, renewal and plan status data;
information provided to support or in reports.

ARCH will not use the microphone, audio recording or private messages between users.

5. Sensitive data

Some data processed by ARCH may be considered sensitive, especially data related to health, heart rate, allergies, intolerances, body measurements, body composition and progress photos.

The collection and use of this data will depend on a separate, specific, prominent and revocable authorization, not bundled with acceptance of the Terms of Use or this Policy.

Refusing or revoking consent will not prevent the use of features that do not depend on this data.

6. How we use the data

We use the data to:

create and manage your account;
provide nutrition, training and progress features;
calculate goals and display history;
generate diet, training and follow-up suggestions;
enable integrations with Apple Health, Strava and Samsung Health;
record activities and, when authorized, location and routes internally;
enable posts, comments, likes, followers, groups and rankings;
display content according to your visibility settings;
send operational notifications, reminders, social interactions and security alerts;
process subscriptions and validate the Free or Pro plan;
prevent fraud, abuse, spam and rule violations;
moderate content and review reports;
diagnose failures and improve stability and security;
comply with legal obligations and exercise rights in legal proceedings;
respond to support and privacy requests.

We will not use health, food, workout, photo or body composition data to target advertising.

7. Artificial intelligence

ARCH may use OpenAI and Anthropic, alternately, for functions such as workout generation, nutrition suggestions and body progress analysis.

Progress photos are not sent to AI providers.

For AI readings (body progress and workout progress, paid plan), only after you allow it in the app itself, we send the AI provider only a calculated summary of your workout, weight, body fat percentage and measurement records, without your name, e-mail, photos or any other direct identifier. You can turn this reading off at any time in the Workouts settings.

Whenever technically and contractually available, we will require:

that the data not be used to train the models;
no retention after processing is complete;
security measures compatible with the sensitivity of the data;
processing limited to the requested purpose.

ARCH will not use users’ personal data to train artificial intelligence models.

AI responses are informational and educational. They do not constitute a diagnosis, prescription, medical consultation, nutritional consultation or professional follow-up.

AI must not be used as a substitute for a physician, nutritionist, physical education professional or other qualified professional.

8. Progress photos

ARCH lets users record photos of their own physical progress. The photos are only stored, so that users can view and compare them over time.

ARCH does not analyze progress photos, whether through artificial intelligence or any other automated means. Any assessment of progress is made by the user.

ARCH will not perform facial recognition, biometric identification or biometric profiling.

Users retain ownership of the photos, posts, comments and other content they publish.

By publishing content, you grant ARCH a limited, non-exclusive and necessary authorization to store, process, display, distribute within the app, moderate and make available the features you choose.

This authorization does not transfer ownership of the content and does not allow it to be sold or used to train artificial intelligence.

Progress photos and posts may contain fitness-context partial nudity, such as bikinis, swim briefs, underwear or a bare torso.

The following are prohibited:

explicit nudity;
pornographic or sexualized content;
exposure of genitals or anus;
content intended for sexual arousal;
any nudity involving minors;
illegal content or content that violates the rights of third parties.

Content may be automatically analyzed, reported, removed or submitted to human review.

10. Visibility of posts

On the Free plan, the profile will be public and posts may be displayed to all users, according to the app’s features.

On the Pro plan, the user may choose between:

all users;
approved followers.

There will be no custom restricted list, view-once posts or specific screenshot detection mechanism.

Private progress photos will remain accessible only to the user, unless they choose to share them.

When the user deletes a post, comment, like or account, the content will be hidden and will no longer appear normally in the app.

ARCH may keep internal copies for at least 90 days to handle reports, investigations, fraud, security, auditing or legal obligations.

After this period, the data will be deleted, unless there is a legitimate basis for further retention.

If there is a report, investigation, legal proceeding or legal obligation, retention may last until the corresponding matter is concluded.

12. Location

Precise location may be collected only during a physical activity started by the user and while that activity is in progress, including in the background when necessary for recording.

Collection will stop when the activity is finished or canceled.

Approximate location may be used to recommend or organize groups, people and activities by region.

Approximate location while in use (optional). If you accept, ARCH obtains an approximate location of your device only while you are using the app, never in the background. We store the city, state and country, and a rounded geographic point (accuracy of about 11 km), never the address or exact coordinates. The update happens at most once a day or when you change cities. We use this data to understand which regions users come from and to improve the app (internal statistics). It is linked to your account, visible only to the ARCH team, not shown to other users, not used for advertising and not sold. You can turn it off at any time in Settings → Privacy and security; when you turn it off or delete your account, the record is erased. This authorization is separate from the Terms of Use and this Policy.

ARCH will not display maps, routes or exact start and end points in shared posts.

13. Health and fitness integrations

ARCH may offer integrations with Apple Health, Strava and Samsung Health.

Apple Health. With your authorization, ARCH:

reads your weight, steps and active energy for the day from Apple Health, only to show them in the app’s summary, on your device;
writes to Apple Health the workouts completed in ARCH (type and duration; distance when available), weight, body fat percentage, water and the daily total of calories, protein, carbohydrates and fats recorded in the app. Writing is part of the Pro plan.

Data read from Apple Health is not sent to our servers, is not used by the artificial intelligence feature, is not used for advertising or shared with third parties, and is not stored in iCloud by ARCH.

Before any reading or writing, ARCH asks for specific consent for health data, separate from the Terms of Use and this Policy. We record the date and the version of the accepted text (see section 21). You choose on Apple’s screen which data types to allow and can change this at any time in Settings → Health → Data Access & Devices, or by turning off the integration in ARCH.

The user may deny or revoke authorization directly in the app or on the integrated platform.

When authorization is revoked, ARCH will stop receiving new data, but may keep previously processed data until the user requests its deletion, subject to the legal retention cases.

14. Contacts

Access to contacts will be optional and may be used to find or invite friends.

The matching will be performed on the device whenever technically possible. ARCH will not store or send the full contact list to the server.

15. Advertising

The Free plan may display ads provided by Google and Meta, alternating according to geographic region.

Ads will be contextual and not personalized. ARCH will not request tracking across apps or websites for advertising.

We will not use weight, measurements, allergies, food, heart rate, photos, workouts or other health information to select ads.

We may block categories incompatible with the app’s health and wellness purpose, such as gambling, tobacco, pornography and certain foods or products considered inappropriate for the context of the service.

The Pro plan will not display ads.

16. Diagnostics and technical security

ARCH may use Sentry to identify crashes, errors and performance problems.

Sentry should receive only the technical data and pseudonymized identifiers necessary for diagnostics.

ARCH should not send Sentry photos, health data, meal content, AI conversations, passwords, tokens or social content.

Detailed technical logs, including IP address and device identifiers when necessary, will be kept for up to 90 days, except in case of incident, investigation or legal obligation.

17. Payments and subscriptions

Subscriptions may be purchased through the Apple App Store or the Google Play Store.

ARCH will not store the full payment card number.

Apple and Google may process payments, receipts, renewal, cancellation, refunds and taxes according to their own policies.

ARCH will receive only the information necessary to validate the plan, the trial period, the subscription and its benefits.

We may share strictly necessary data with:

Supabase, for authentication, database, storage and infrastructure;
OpenAI and Anthropic, for authorized artificial intelligence features;
Sentry, for technical diagnostics;
Google and Meta, for contextual ads on the Free plan;
Apple and Google, for authentication, payments and subscriptions;
Apple Health, Strava and Samsung Health, when the user authorizes it;
support, security, hosting and moderation providers;
public authorities, when there is a legal obligation, court order or valid request;
third parties involved in a merger, acquisition or reorganization, with appropriate protection measures.

We do not sell, rent or trade personal data.

19. International transfers

Although Supabase is initially hosted in Brazil, some providers, such as OpenAI, Anthropic, Sentry, Google, Meta, Apple or Google Play, may process data outside Brazil.

In these situations, ARCH will adopt valid international transfer mechanisms, contractual clauses, technical measures and safeguards compatible with the LGPD, the GDPR and other applicable laws.

The transfer will be limited to the data necessary for the stated purpose.

20. Security

We adopt reasonable technical and administrative measures to protect data against unauthorized access, loss, destruction, alteration, disclosure or misuse.

Data is protected with encryption in three layers:

in transit, all communication between the app and the servers uses a secure connection (HTTPS/TLS);
on the server, data is stored with AES-256 encryption by the database provider (Supabase);
on iPhone, progress photos and data kept on the device use iOS file protection, which keeps them encrypted while the device is locked, and sign-in credentials are stored in the iOS Keychain.

Beyond encryption, we use access control, segregation of permissions, audit logs, pseudonymization where applicable, monitoring and security reviews.

No system is completely invulnerable. Users should also protect their credentials and use a secure device.

In the event of a relevant incident, ARCH may notify the ANPD (Brazilian National Data Protection Authority), other authorities and affected users when required by applicable law.

21. Consents and auditing

ARCH may record:

date and time of consent;
version of the Policy or authorization presented;
authorized purpose;
action taken;
revocation of consent;
IP address, device identifier and related technical data, when necessary.

Essential consent records will be kept for as long as necessary for legal proof.

Detailed technical logs will be kept for 90 days, except in case of incident, investigation or legal obligation.

22. User rights

Under applicable law, you may request:

confirmation that processing exists;
access to the data;
correction of incomplete or incorrect data;
information about sharing;
anonymization, blocking or deletion, where applicable;
revocation of consents;
portability or export of the data;
objection to certain processing;
review of decisions made solely by automated means, where applicable;
information about international transfers;
individual deletion of photos, reports, posts, workouts, meals and other data.

23. How to exercise your rights

You may request access, correction, export, revocation or deletion:

directly in the app, when the feature is available; or
by e-mail at privacidade@assincrono.com.

We may request additional information to confirm the requester’s identity and protect the account against fraud.

We will respond to requests within the time limits set by applicable law.

You may also file a complaint with the competent data protection authority, including the ANPD, if you believe your rights have not been respected.

24. Automated decisions

ARCH may use automation to generate suggestions, analyses, recommendations, alerts and organization of information.

We will not make decisions based solely on automated processing that have legal effects or a significant impact on the user.

Automatic changes to goals, diet, workouts or routine will require express confirmation before being applied.

25. Account deletion

The user may delete the account through the app or by e-mail.

After the request, the data and content will be hidden and inaccessible in the app.

The data may remain internally for at least 90 days for reports, security, auditing, investigation, fraud prevention or compliance with legal obligations.

After this period, it will be deleted, anonymized or kept only when there is a legal basis for further retention.

26. Changes to this Policy

We may update this Policy to reflect legal, regulatory, technical, business or product changes.

The current version will indicate the date of the last update.

When a change is relevant, we may notify the user through an in-app notice, e-mail or other appropriate channel.

No relevant new purpose will be implemented without updating the necessary information and authorizations.

27. Contact

Privacy-related questions, requests or complaints may be sent to:

Responsible party: ASSINCRONO LTDA · CNPJ 69.619.850/0001-79
Data Protection Officer (DPO): privacidade@assincrono.com
E-mail: privacidade@assincrono.com
Address: Curitiba/PR
Country: Brazil