Privacy Policy

Last Updated: April 29, 2026

This Privacy Policy outlines how we collect, use, and disclose your personal information when you interact with our services. It also explains your privacy rights and how applicable laws protect you.

By using our services, you consent to the collection and use of your personal information as described in this Privacy Policy.

Interpretation & Definitions

Interpretation

Terms with capitalized initials hold specific meanings as defined below, regardless of whether they appear in singular or plural form.

Definitions

• Account – A unique profile created for you to access our services.
• Affiliate – Any entity that controls, is controlled by, or shares common control with another entity, where "control" means ownership of at least 50% of voting securities.
• Application – Any software or program provided by the Company, including but not limited to FitnessGPT.
• Company – "We," "Us," or "Our," meaning Gradient Descent Labs, a division of Gradient Descent LLC, 1309 Coffeen Avenue.
• Country – Refers to Wyoming, United States.
• Device – Any device capable of accessing our services, such as computers, smartphones, or tablets.
• Personal Data – Any data that can identify an individual.
• Service – Refers to the application or software provided by the Company.
• Service Provider – Any individual or organization processing data on our behalf.
• Usage Data – Information collected automatically about how the service is accessed and used.
• You – The individual using our service, or the company or legal entity they represent.

Collection & Use of Your Personal Data

Types of Data Collected

Personal Data

When using our services, we may request personal details to identify or contact you. This may include, but is not limited to:

• Name
• Email address
• Contact information

Usage Data

We automatically collect certain data related to service usage, including:

• Device's IP address
• Browser type and version
• Pages visited and time spent on them
• Unique device identifiers

If accessing via a mobile device, we may gather additional details such as:

• Mobile device type
• Mobile operating system
• Internet browser type
• Unique device identifiers

Your browser or mobile device may also send data when interacting with our service.

Health & Fitness Data (HealthKit)

FitnessGPT integrates with Apple HealthKit to provide personalized nutrition and fitness coaching. With your permission, we may access the following categories of health and fitness data from HealthKit:

• Body measurements (height, weight, body mass index)
• Activity data (steps, workouts, active energy burned)
• Nutrition data (dietary intake logs)
• Other health metrics you choose to share with the app

How We Use HealthKit Data

Health and fitness data accessed through HealthKit is used solely to provide and improve the features of FitnessGPT, including generating personalized nutrition recommendations and coaching insights.

Managing Your Health Data

You can revoke the app's access to HealthKit at any time through your device's Settings → Privacy & Security → Health. You may also request deletion of any health data we have stored by contacting us at hello@gradientdescentlabs.com.

Advertising & Tracking (App Tracking Transparency)

FitnessGPT uses Apple's App Tracking Transparency (ATT) framework. When you first use the app, we will ask for your permission before engaging in any activities that fall under Apple's definition of tracking.

What We Use Tracking For

If you grant tracking permission, we may use your device's Advertising Identifier (IDFA) and related signals to:

• Measure the effectiveness of our own advertising campaigns (e.g., to understand which ads led to app installs or subscriptions).
• Optimize the delivery of our own ads on third-party platforms such as Meta (Facebook/Instagram) and Google.

Third-Party Advertising SDKs

To facilitate advertising measurement and optimization, our app includes the following third-party SDKs:

• Meta SDK (Facebook/Instagram) — used to measure and optimize our ad campaigns on Meta platforms.
• Tenjin SDK — used for mobile attribution and campaign analytics.
• SKAdNetwork — Apple's own privacy-preserving attribution framework, used as a baseline measurement tool regardless of your ATT choice and without accessing your IDFA.

The Meta and Tenjin SDKs operate subject to your ATT permission status. If you deny tracking permission, these SDKs will function in a limited, non-tracking mode and will not access your IDFA.

Your Choices

You may grant or revoke tracking permission at any time through your device's Settings → Privacy & Security → Tracking. Denying tracking permission will not affect your ability to use FitnessGPT's core features.

How We Use Your Data

We utilize personal data for:

• Service operation & maintenance – Monitoring and improving functionality.
• Account management – Enabling access to features available to registered users.
• Contract fulfillment – Processing transactions and service agreements.
• Communication – Sending updates, security notices, and account-related messages.
• Marketing & promotions – Providing news, offers, and information relevant to your interests (unless opted out).
• User support – Addressing inquiries and requests.
• Business transactions – Evaluating mergers, acquisitions, or asset transfers.
• Other purposes – Conducting data analysis, monitoring trends, and improving services.

Data Retention & Transfer

Retention

We retain your personal data only as long as necessary for stated purposes or to comply with legal obligations. Usage data is typically stored temporarily unless needed for security, service improvement, or legal compliance.

Transfer

Your information, including personal data, may be processed and stored in locations outside your jurisdiction, where data protection laws may differ. By submitting data, you consent to such transfers. We implement safeguards to ensure your data is handled securely and in accordance with this Privacy Policy.

Your Rights: Managing & Deleting Your Data

You have the right to access, correct, or delete your personal data. Within our service, you may manage your information in your account settings or contact us for assistance. However, certain data may be retained as required by law or for legitimate business purposes.

Disclosure of Your Data

Business Transactions

If involved in a merger, acquisition, or asset sale, your personal data may be transferred. We will notify you before such a transfer occurs.

Legal Compliance

We may disclose personal data if required to:

• Comply with legal obligations.
• Protect Company rights and property.
• Investigate potential misconduct.
• Ensure user and public safety.
• Defend against legal claims.

Data Security

We take security seriously and implement reasonable measures to protect your personal data. However, no transmission or storage method is 100% secure, so we cannot guarantee absolute protection.

Children's Privacy

Our services are not intended for children under 13, and we do not knowingly collect personal information from them. If you believe a child has provided us with data, please contact us, and we will take steps to remove it.

Third-Party Links

Our services may contain links to third-party websites. We do not control their privacy practices and encourage you to review their policies.

Privacy Policy Updates

We may update this Privacy Policy periodically. Changes will be posted here, and we will notify you via email or a service notice before they take effect. The "Last Updated" date at the top reflects the latest revision.

You are encouraged to review this policy regularly.

Contact Us

If you have questions about this Privacy Policy, reach out to us:

Email: hello@gradientdescentlabs.com