⚠️ DRAFT — requires review by a qualified attorney before launch. This document was prepared as a comprehensive starting point. The health-data, AI, payments, and international-transfer sections in particular should be confirmed by counsel for your final entity and markets.

Placeholders still to fill in (see llc-formation-plan.md): [EFFECTIVE DATE].

Shojin Privacy Policy

Last updated: [EFFECTIVE DATE] Effective: [EFFECTIVE DATE]

This Privacy Policy explains how Shojin Fitness LLC ("Shojin," "we," "us," or "our") collects, uses, shares, and protects personal information when you use the Shojin mobile application (the "App"), the Shojin coach web portal (the "Portal"), and any related websites, features, and services (together, the "Services").

Shojin is a fitness and nutrition tracking platform. Because the Services process health and fitness information, we treat that data with heightened care, as described below.

By using the Services, you agree to this Privacy Policy. If you do not agree, do not use the Services. This Policy is incorporated into our Terms of Service.

1. Quick summary

This summary is for convenience only and does not replace the full Policy.

What we collect: account details, profile and body metrics, the workouts, nutrition, weight, and steps you log, health data you choose to sync from Apple Health or Android Health Connect, food photos you submit for AI analysis, payment and payout information, content you create or buy, and technical/usage data.
Why: to provide and operate the Services, sync your health and fitness data, run the marketplace and coaching features, process payments and creator payouts, analyze food photos with AI, keep the Services secure, comply with law, and (only with your consent where required) communicate with you.
Who we share with: service providers ("sub-processors") such as Supabase, Apple, Google, RevenueCat, Stripe, Anthropic, Expo, and Notion; other users for content you choose to make public; and authorities where legally required. See Section 7 and sub-processors.md.
We do not sell your personal information, and we never use health data for advertising.
Your choices: access, correct, export, or delete your data; withdraw consent; manage health and notification permissions on your device. See Section 11.
Minimum age: 16. The Services are not for anyone under 16.
Contact: privacy@shojinfitness.com.

2. Who is responsible for your data (Controller)

The controller of your personal information is:

Shojin Fitness LLC 1500 N Grant St, Ste C Denver, CO 80203, USA privacy@shojinfitness.com

When a coach uses the Portal to manage their own clients, the coach may act as an independent controller of the client information they enter or receive. Shojin acts as a processor on the coach's behalf for that activity and as a controller for our own platform operations.

3. The information we collect

We collect the following categories of information.

3.1 Information you provide directly

Account information: name, email address, password (stored hashed by our authentication provider), and, if you sign in with Google or Apple, the basic profile identifiers those providers share.
Profile and fitness goals: date of birth or age, sex, height, weight, activity level, units preference, training and nutrition goals, and similar onboarding details.
Logged fitness and nutrition data: workouts, exercises, sets, reps, loads, routines, completed workout sessions, foods and meals logged, recipes, meal plans, weight entries, and step counts entered manually.
Food photos: images you submit to the AI food-logging feature for nutritional estimation (see Section 5).
User-generated content: foods, recipes, workouts, and routines you create; ratings; likes/dislikes; and anything you choose to publish or list for sale.
Payment and payout information: for purchases, our payment processors (Apple, Stripe) collect and process your payment details; for creators and coaches receiving payouts, Stripe collects identity, bank/payout, and tax information required to pay you. We receive limited transaction metadata, not full card numbers.
Support, feedback, and bug reports: the content of messages, feature requests, and issue reports you submit (which may be routed to our internal tracking tool).

3.2 Health and fitness data from connected sources

With your permission, the App can read data from Apple Health (HealthKit) on iOS and Android Health Connect — for example step counts and related activity metrics — to populate your dashboard and reduce manual entry. You control this access through your device's health-permission settings and can revoke it at any time.

We treat health and fitness data as sensitive / special-category personal information and apply the additional protections described in Section 6 and Section 12.

3.3 Information collected automatically

Device and technical data: device model, operating system, app version, language, and similar diagnostic information.
Usage data: features used, screens viewed, and actions taken within the Services, used to operate and improve them.
Log and security data: IP address, timestamps, and error/crash information collected by our infrastructure providers for security, debugging, and reliability.
Push notification tokens: if you enable notifications, a device token used to deliver them.

We describe cookies and similar technologies on the web Portal in Section 9.

3.4 Information from third parties

Authentication providers (Google, Apple) when you choose to sign in with them.
Payment and payout providers (Apple, RevenueCat, Stripe) regarding the status of purchases, subscriptions, entitlements, and payouts.
Other users, for example a coach who invites you as a client, or interactions on content you have published.

4. How we use your information

We use personal information to:

Provide the Services: create and manage your account; store and display your workouts, nutrition, weight, and steps; sync connected health data; and enable routines, meal plans, and analytics.
Operate the marketplace: list, browse, buy, and sell routines, workouts, and recipes; manage entitlements and ownership; and process creator payouts.
Operate coaching: connect coaches and clients, deliver assigned routines, and manage coaching subscriptions and billing through the Portal.
Provide AI features: analyze food photos you submit to estimate foods and nutrition (see Section 5).
Process payments: complete purchases and subscriptions and pay creators and coaches.
Communicate with you: send service, transactional, and security messages; respond to support requests; and, where you have opted in or as permitted by law, send product updates.
Secure and improve the Services: prevent fraud and abuse, debug, monitor performance, and develop new features.
Comply with law and enforce our Terms of Service.

4.1 Legal bases (EEA / UK users)

Where the GDPR or UK GDPR applies, we rely on:

Purpose	Legal basis
Providing the Services you request (account, logging, marketplace, coaching)	Contract (Art. 6(1)(b))
Processing health and fitness data and food photos	Explicit consent (Art. 9(2)(a)); withdrawable at any time
Payments, payouts, tax, and recordkeeping	Legal obligation (Art. 6(1)(c)) and contract
Security, fraud prevention, and improving the Services	Legitimate interests (Art. 6(1)(f))
Optional marketing communications	Consent (Art. 6(1)(a))

You can withdraw consent at any time without affecting processing already carried out. Withdrawing consent for health data or AID features may limit functionality.

5. AI features

The App offers an AI food-logging feature. When you choose to use it, the photo(s) you submit are sent to our AI provider, Anthropic, which analyzes the image(s) and returns estimated foods, portions, and nutrition values.

We send the image(s) and a processing prompt; we do not send your name or account identifiers to the AI provider as part of the food analysis.
Anthropic processes the images to generate the response and, under our agreement, does not use your inputs or outputs to train its models.
AI-generated nutrition values are estimates only and may be inaccurate. They are not medical, dietary, or professional advice. Always verify before relying on them.
Using the AI feature is optional; you can log foods manually instead.

See sub-processors.md for the current AI provider details.

6. Health and fitness data

Much of what Shojin stores — body metrics, workouts, nutrition, weight, steps, and health data synced from Apple Health or Health Connect — is health and fitness information. We give it special protection:

We process it to provide the Services you request, and, where required by law, only with your explicit consent.
We never use health or fitness data for advertising or marketing, and we do not sell it.
Data read from Apple HealthKit is used solely to provide the in-app features you enable, is never shared with third parties for advertising or data-broker purposes, and is handled in accordance with Apple's HealthKit requirements. Data read from Android Health Connect is likewise handled in accordance with Google's Health Connect requirements.
You can revoke health-source access at any time in your device settings; this stops future syncing but does not delete data already stored in your account (you can delete that separately — see Section 11).

We do not sell your personal information. We share it only as described here.

Service providers (sub-processors): companies that host, process, or support the Services under contract, including Supabase (database, auth, storage), Apple and Google (authentication, in-app purchases, push), RevenueCat (in-app purchase management), Stripe (payments and payouts), Anthropic (AI food analysis), Expo (push notification delivery), and Notion (internal feedback/issue tracking). A current list is maintained in sub-processors.md.
Other users: content you choose to make public or list for sale (e.g., a public recipe or a marketplace routine) is visible to other users, along with associated ratings and aggregate like/dislike counts. Your private logs are never shared this way.
Coaches and clients: if you accept a coaching relationship, relevant training and progress information is shared between you and your coach to deliver coaching.
Payments and payouts: transaction and tax information is shared with our payment processors as needed to complete purchases and pay creators/coaches.
Legal and safety: to comply with law, respond to lawful requests, enforce our terms, or protect the rights, safety, and property of Shojin, our users, or the public.
Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy.

We do not share health or fitness data with third parties for their own marketing.

8. International data transfers

Shojin and its providers may process and store information in the United States and other countries that may have different data-protection laws than your own.

Where we transfer personal information out of the EEA, UK, or Switzerland, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses (and the UK Addendum), or another lawful transfer mechanism. You may request a copy of the relevant safeguards by contacting privacy@shojinfitness.com.

9. Cookies and similar technologies

The mobile App does not use advertising cookies. It uses local device storage to keep you signed in and to remember preferences and pending purchases.

The web Portal uses strictly necessary cookies/local storage for authentication and session management. If we add analytics or other non-essential technologies to the Portal, we will update this section and, where required, request consent.

10. Data retention

We keep personal information for as long as your account is active or as needed to provide the Services, and afterward only as required to:

comply with legal, tax, and accounting obligations (for example, payment and payout records);
resolve disputes and enforce our agreements; and
maintain security and prevent abuse.

When you delete your account, we delete or de-identify your personal information within a commercially reasonable period, except where retention is required by law. Food photos submitted for AI analysis are not retained by us beyond what is needed to return the result, except as part of your saved log if you save the result. Backups are purged on a rolling schedule.

11. Your privacy rights

Subject to your location and applicable law, you may have the right to:

Access the personal information we hold about you and obtain a copy;
Correct inaccurate or incomplete information;
Delete your information (you can delete your account in Profile → Settings → Delete Account);
Export / portability — receive your data in a portable format;
Restrict or object to certain processing;
Withdraw consent where processing is based on consent (including health data and AI features);
Opt out of any "sale" or "sharing" of personal information and of certain profiling — note we do not sell or share personal information as those terms are defined under applicable US laws; and
Lodge a complaint with your local data-protection authority.

To exercise these rights, use the in-app controls or contact privacy@shojinfitness.com. We will verify your request and respond within the timeframe required by law. We will not discriminate against you for exercising your rights. You may use an authorized agent where the law permits.

12. Region-specific disclosures

Our legal bases are listed in Section 4.1. Health and fitness data and food photos are special-category data processed on the basis of your explicit consent. You have the rights in Section 11, including the right to complain to your supervisory authority.

12.2 California (CCPA/CPRA)

In the preceding 12 months we have collected the categories of personal information described in Section 3, including sensitive personal information (account credentials and health information), which we use only to provide the Services and for the purposes in Section 4 — not to infer characteristics for advertising. We do not sell or share personal information as those terms are defined under the CCPA/CPRA, and we do not knowingly process the data of consumers under 16 for sale. California residents have the rights to know, delete, correct, and limit the use of sensitive personal information, and the right to be free from discrimination for exercising them. Submit requests to privacy@shojinfitness.com.

12.3 Other US states and other jurisdictions

Residents of other US states with comprehensive privacy laws (e.g., Virginia, Colorado, Connecticut, Texas) and users in other jurisdictions may have similar rights to access, correct, delete, and obtain a copy of their data, and to opt out of targeted advertising or sale (which we do not conduct). Contact privacy@shojinfitness.com to exercise them.

13. Children's privacy

The Services are intended for users 16 and older. We do not knowingly collect personal information from anyone under 16. If you believe a person under 16 has provided us personal information, contact privacy@shojinfitness.com and we will delete it.

14. Security

We use technical and organizational measures appropriate to the sensitivity of the data, including encryption in transit, access controls, row-level security on user data, and use of reputable infrastructure providers. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. Protect your account by using a strong, unique password and keeping your devices secure.

15. Third-party services and links

The Services integrate with and link to third parties (e.g., Apple, Google, Stripe, your coach's tools). Their handling of your information is governed by their own privacy policies, which we encourage you to review. We are not responsible for the practices of third parties.

16. Changes to this Policy

We may update this Policy from time to time. When we make material changes, we will update the "Last updated" date and, where required, notify you in the App or by email. Your continued use of the Services after an update means you accept the revised Policy. Prior versions are tracked in CHANGELOG.md.

17. Contact us

Questions, requests, or complaints about privacy:

Shojin Fitness LLC Attn: Privacy 1500 N Grant St, Ste C Denver, CO 80203, USA privacy@shojinfitness.com https://shojinfitness.com

For EEA/UK matters, you may also contact your local data-protection authority.