Privacy Policy

In order to use our apps or websites, we may ask you to provide your name, email address, weight, height, fitness level, areas for improvement, food preferences, and other onboarding information depending on the app or web product you select from our ecosystem (for example, certain mental wellness information may be required to use our mental wellness app). In some of our apps, you may skip certain onboarding questions by selecting “Skip” or a similar option.

We may also automatically collect the following information from your device: language settings, IP address, time zone, device type and model, device settings, operating system, and other technical information. We use this data to provide our services (for example, to render specific product features), to analyze how users interact with the app (for example, to determine whether released features are used), and to serve advertisements. In most cases, you may influence such processing by adjusting privacy settings available within our websites and/or apps.

Please refer to our Privacy Policy below to learn more about how we process personal data (Section 2) and what privacy rights are available to you (Section 4). Depending on your region and the selected product, we strive to provide various privacy control features and rights. For example:
• Manage online tracking via e-Privacy settings in our apps or websites.
• Opt out of the sale or sharing of data (as defined under applicable US laws).
• Request deletion of your data and account.
• Exercise other applicable privacy rights.

Where such features are available, they will be clearly presented in footers, menus, or profile sections of our products. We aim to provide most privacy rights through simple, user-friendly interface features. If you are unable to locate or access such features, or if they are unavailable, you may submit a request to us.

If you have any questions or wish to exercise your privacy rights, please contact us at taichi.help@proton.me.

This Privacy Policy explains what personal data is collected when you use our mobile applications, websites, and related services (together, the “App” or “Service”), and how such personal data is processed.

By using the Service, you confirm that (i) you have read, understood, and agree to this Privacy Policy and the described data processing, and (ii) you are over 18 years of age. If you do not agree or are unable to make this confirmation, you must not use the Service. In such case, you must (a) delete your account and contact us to request deletion of your data; (b) cancel any subscriptions using the functionality provided by Apple (if you use iOS), Google (if you use Android), any other app stores that may be available from time to time, or by us if you purchased the Service directly through our websites; and (c) delete the App from your devices.

Any translation of the English version is provided for convenience and transparency purposes only. In the event of any discrepancy or difference in interpretation between the English version of this Privacy Policy available at https://www.intercom.com/legal/privacy and any translation, the English version shall prevail. The English text shall be the sole legally binding version.

We process data:

(i) that you directly provide to us (for example, when you select your areas for improvement, send us an email, or interact with our coaches),(ii) that we receive from third parties (for example, when you sign in via Apple or grant us access to Apple Health or Health Connect data), and(iii) that is collected automatically when you use our Service (for example, your IP address through cookies or SDK technologies).

1. Identifiers
This category may include your name, phone number, and email address. You provide this information when you register for the Service, purchase our physical products, subscribe to our newsletters, or contact us through any other means.

2. Onboarding and product data
You provide this category of information when you register for the Service, complete the onboarding process, and/or use the Service. This may include, in particular:

• General information about you. For example, age, date of birth, gender, country, etc.

• Wellness and fitness information. This includes physical characteristics such as height and weight, workout data, meditation and breathing preferences, sleep patterns, and the type and duration of physical activities you perform. We may also request information about your fitness level or nutritional preferences, or allow you to track water and food intake, including by uploading photos of meals. We use selected elements of this data to personalize your experience as part of the services provided.

• Special wellness data. Certain information may be considered a special category of personal data or sensitive data under applicable laws. This may include, for example, information about whether you require a diabetes meal plan, whether you opt into a limb-loss program, or whether you use cycle tracking features. In such cases, we will seek your consent for processing where required.

3. Commercial information
When you make payments through the Service, you are required to provide financial information, such as your credit card details, to our third-party payment service providers. We do not collect, store, or have access to full payment card numbers. However, we may receive limited information such as a secure payment token, details about purchased products or services, transaction date, time, and amount, payment method type, and partial card information.

4. Comments and attachments provided with requests
You may also provide personal information when using “Contact us” forms or when communicating via email (including through communication service providers referenced in Section 3). This may include any information or comments included in your inquiry.

1. Apple ID account
‍When you sign in with Apple to create an account in the App, we receive certain personal data from your Apple ID account, such as your name and verified email address. You may choose to share your real email address or an anonymized address using Apple’s private email relay service. Apple provides detailed privacy information during the sign-in process. More information about Sign in with Apple is available from Apple.

1. Online activity
We record how you interact with our Service. This may include interactions with interface elements, features and content, completed workouts, workout duration and timing, meditation activities, frequency and duration of app usage, training or meditation progress, and subscription-related activity.

2. Device and geolocation data
We collect data from your mobile device, which may include language settings, IP address, time zone, device type and model, device settings, operating system, internet service provider, mobile carrier, hardware ID, and Facebook ID. Where you provide consent in certain products, we may also collect geolocation data (for example, for running routes).

3. Advertising identifiers
We collect your Apple Identifier for Advertising (IDFA) or Google Advertising ID (AAID), depending on your device’s operating system. You may reset these identifiers through your device settings; however, we do not control this process.

4. Cookies and similar tracking technologies
Our products use cookies, SDKs, and similar technologies to process data in order to improve user experience, optimize advertising, and analyze traffic. These technologies are activated when you use our services, visit our website, use our apps, or enable specific features such as chats. Disabling them may affect certain functionalities, but the products will generally remain usable.We and our partners also use targeting technologies to personalize advertising and measure campaign effectiveness. This may result in ads being displayed to you on third-party platforms, such as social media.
We respect your privacy and provide options to limit processing that is not strictly necessary for service delivery. We use the following categories of tracking technologies:

Strictly necessary
These technologies are required for the proper functioning of our products and are typically activated when you use the Service. They allow us to:
• remember your preferences while navigating the Service,
• ensure fast content loading,
• enhance security, and
• enable core functionality, including customer support and chat features.

Functional
These technologies enhance and personalize your experience by remembering your preferences (such as language or design settings) and maintaining session continuity (for example, keeping you logged in or storing cart selections). If disabled, some features may not function properly.

Performance
These technologies help us understand how users interact with the Service by collecting aggregated usage information, such as:
• visit counts and traffic sources,
• most used features or sections,
• user behavior patterns and preferences,
• If disabled, we may not receive certain analytical data.

Targeting
These technologies are used to deliver personalized advertising and measure advertising performance. If disabled, you may receive less relevant ads, and our ability to measure campaign effectiveness may be limited.If you are located in certain jurisdictions, you may adjust your tracking preferences via a dedicated consent banner.

We collect and use your data primarily to deliver our services, improve the quality of our fitness and wellness offerings, and continuously enhance them. In addition, we use data to help attract new users to our products. Below, you will find a more detailed explanation of how your information is used, including illustrative examples.
Please also note that certain information we collect, including onboarding and product-related data, may be considered a special category of personal data or sensitive data under applicable data protection laws to which we are subject.

Description and examples:
This includes verifying your identity and email address, enabling you to access and use the Service smoothly, and preventing or resolving technical issues or errors. It also includes personalizing your experience.
Personalization means adapting the content of the Service to your preferences. For example, you may receive a nutrition plan focused only on vegetarian products or a customized meal plan offered via in-app chat that is aligned with your goals.
We also process your data to respond to your requests for technical or customer support, Service-related information, or any other inquiries you initiate. This may include accessing your account to investigate and resolve support requests, providing detailed responses to your questions, ensuring satisfaction with the Service, and handling any disputes related to the Service.

Notifications:
We may send you notifications or emails regarding Service performance, security updates, payment transactions, or updates to our Terms and Conditions or Privacy Policy.

Events:
We may process your data if you participate in in-app challenges, offline community events, giveaways, or similar activities subject to additional terms and conditions.

Categories of personal data:
All categories of data.

Lawful basis:
Performance of a contract with you, or consent where processing involves a special category of personal data in a relevant jurisdiction.

Description and examples:
We communicate with you through various channels, including push notifications. These may contain reminders and motivational messages encouraging you to follow your training or nutrition plan, as well as other Service-related information such as password reset instructions or account updates. For example, you may receive a daily push notification at a scheduled time reminding you to complete a workout. You can opt out of push notifications by adjusting your device settings.We may also contact you to inform you about important updates or changes to the Service, to collect feedback, or to respond to your inquiries or complaints.

Categories of personal data:
All categories of data.

Lawful basis:
Performance of a contract with you, or legitimate interest where such processing is not strictly necessary for the provision of the Service.

Description and examples:
We and our partners use your personal data to tailor advertisements and, where appropriate, display them at relevant times. For example, if you have installed our Service, you may see advertisements for our products within platforms such as Instagram.

Categories of personal data:

• Onboarding and product data
• Online activity
• Commercial information
• Tai Chi Walking for Beginners purchase data
• Device and geolocation data
• Advertising identifiers (for example, may also be used for preventing or resolving technical issues)
• Cookies and similar tracking technologies

Lawful basis:
Legitimate interest (or consent where required under applicable e-Privacy or similar regulations).

Description and examples:
This includes conducting audits related to counting ad impressions and unique visitors, verifying the placement and quality of advertisements, and ensuring compliance with applicable specifications, standards, and requirements.

Categories of personal data:

• Identifiers
• Onboarding and product data
• Online activity
• Commercial information
• Device and geolocation data
• Advertising identifiers
• Cookies and similar tracking technologies

Lawful basis:
Legitimate interest (or consent where required under applicable e-Privacy or similar regulations).

Description and examples:
We collect and store personal data to the extent necessary to protect and defend our legal rights and interests in the event of disputes, claims, or legal proceedings. This may include using such data to support legal claims, respond to lawful requests, or establish, exercise, or defend our legal position.

Categories of personal data:
All categories of data.
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Lawful basis:
Legitimate interest.

Description and examples:
We offer paid services within the Service. For this purpose, we use third-party payment service providers. As a result of this processing, you are able to complete payments for our Service, and we receive confirmation that the payment has been successfully completed in order to provide you with the purchased service or product. We do not store or collect your full payment card details.

Categories of personal data:

• Identifiers
• Commercial information
• Device and geolocation data
• Tai Chi Walking for Beginners purchase data
• B2B Service data

Lawful basis:
Performance of a contract with you

Description and examples:
This helps us better understand our business, analyze performance, and maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use this data for statistical analysis and to test and optimize our offerings.

This allows us to understand which features, workouts, and training plans are most popular and which user groups engage with the Service. Based on these insights, we may improve the Service. For example, if we observe that users frequently engage with leg-focused workouts, we may develop and add new workouts targeting that area.

We may also process your data for these purposes if you participate in surveys, interviews, studies, research initiatives, or similar programs.

Categories of personal data:
All categories of data.

Lawful basis:
Legitimate interest (unless consent is required, for example where special categories of personal data are involved or where applicable e-Privacy regulations apply).

Description and examples:
We may include your email address in our marketing communications list, provided we have obtained your consent or otherwise established a lawful basis for sending such communications. As a result, you may receive information about our products, including promotional offers and updates. If you no longer wish to receive marketing emails, you can unsubscribe by following the instructions provided in the footer of each marketing message.

Categories of personal data:
Identifiers

Lawful basis:
Consent or legitimate interest (where permitted under applicable law, including exceptions to consent requirements in certain jurisdictions).

Description and examples:
We may process personal data to comply with applicable legal and regulatory requirements, such as tax, accounting, and other statutory obligations. In particular, we may use your commercial information to calculate and report taxes, issue invoices or receipts, respond to inquiries from tax authorities, and maintain accurate financial records. We may also process data to comply with data protection laws (such as GDPR and CCPA), and to respond to lawful requests from public authorities, law enforcement, or regulatory bodies.

Categories of personal data:
All categories of data.

Lawful basis:
Compliance with legal obligations.

Description and examples:
We use personal data to enforce our agreements and contractual obligations, as well as to detect, prevent, and address fraudulent activity. This may include verifying user identities, monitoring transactions for suspicious behavior, and taking appropriate measures to protect users and the Service from fraud or abuse.

Categories of personal data:
All categories of data.

Lawful basis:
Legitimate interest.

*Legitimate interests:
To communicate with you regarding your use of the Service
This includes, for example, sending push notifications reminding you to exercise at appropriate times. The legitimate interest we rely on for this purpose is our interest in encouraging continued use of the Service. We also consider the potential benefits to you of following your training and nutrition plan, which may support a healthier lifestyle.

To communicate with you regarding possible cooperation
The legitimate interest we rely on for this processing is our interest in establishing and maintaining business relationships with potential partners, clients, or collaborators, enabling access to our programs and offers.

To research and analyze your use of the Service and conduct user research (surveys, interviews)
Our legitimate interest for this purpose is to improve the Service by understanding user preferences and enhancing the overall experience (for example, making the App easier to use, more engaging, and introducing or testing new features).

To send you marketing communications (unless you provide consent)
The legitimate interest for this processing is our interest in promoting the Service in a reasonable and appropriate manner. This may apply, for example, where there is an existing business relationship, including prior purchases within the Service.

To personalize our ads
We rely on our legitimate interest in promoting the Service in a more relevant and targeted manner.

To audit advertising performance
The legitimate interest for this processing is ensuring the accuracy and quality of our advertising services and compliance with industry standards.

To enforce our Terms and Conditions of Use and defend our legal rights and interests
The legitimate interest is to protect the Company from legal disputes, claims, or actions that could affect its operations, reputation, or financial position, as well as to ensure compliance with the Terms and applicable laws. This may include using data to support our position in disputes, respond to legal requests, or provide evidence in legal proceedings.

To prevent and combat fraud
Our legitimate interest for this purpose is to enforce legal rights, prevent and address fraud, and protect against unauthorized use of the Service.

We engage third-party partners to perform specific services and business functions on our behalf, using their technologies and resources in accordance with our instructions. This cooperation may, in particular, involve the processing of your data through software development kits (SDKs), application programming interfaces (APIs), cookies, and other similar technologies. As a result, your information may be transferred to and processed on the servers of such partners (typically without granting them direct access to specific data elements) on our behalf and for our purposes.

Such processing of personal data may be considered as sharing of information with third parties. We endeavor to enter into appropriate data processing agreements with all such third parties in order to define the rules governing the processing of your data strictly on our behalf and within the scope of such purposes. Our partners assist us in operating, providing, improving, integrating, customizing, supporting, and marketing our Service.

The categories of third parties with whom we share information include, in particular:

We disclose personal data to third-party service providers engaged to perform services or business functions on our behalf, in accordance with our instructions. We process your personal information using the following categories of service providers (and, where applicable, their subprocessors):

a. Cloud storage providers
To host personal data and ensure the operation and distribution of our Service, we use Firebase, a hosting and backend service provided by Google. Further information regarding Google’s security practices is available on its official website.

b. Product monitoring service providers
To monitor infrastructure and application performance, we use Crashlytics, a monitoring service provided by Google. Please refer to its Data Collection Policy for further details.

We also use Firebase Performance Monitoring and Firebase Crash Reporting, which are monitoring services provided by Google. Additional information is available in Google’s Privacy Policy and Firebase Privacy and Security documentation.

d. Data analytics providers
Ad performance measurement systems
To conduct research and analysis of user interactions with our App, we use Appsflyer. Appsflyer enables us, in particular, to understand how users discover our Service (for example, which advertiser delivered an advertisement that led to the installation of our App). Appsflyer also provides analytical tools that allow us to study and evaluate your use of the Service. Appsflyer provides an opt-out option for preventing data from being sent from your device to its servers for app usage collection. More information is available in Appsflyer’s Privacy Policy.

General analytics tools
We use Amplitude, an analytics service that allows us to understand how users interact with our Service. Amplitude collects various technical information, including time zone, device type (phone or tablet), and unique identifiers (such as IDFA). It also enables tracking of user interactions within our App. This helps us determine which features to prioritize (for example, if walking meditation workouts are most frequently used, we may develop additional similar content). Amplitude complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”). Further information is available in its Privacy Policy.

To analyze website usage and measure advertising effectiveness, we use Google Analytics, a web analytics service provided by Google. Through Google Analytics, we receive information such as user interactions and data entered on our website. Google provides tools allowing users to control data collection, including a browser add-on. More information is available in Google’s documentation.

To analyze user behavior within our App (for example, responses to changes in structure, text, or other elements), we use Firebase Remote Config. This service also enables A/B testing and content customization (for example, displaying different onboarding flows to different users). Further details are available in Firebase Privacy Policy and Firebase Privacy and Security documentation.

e. Payment gateway and processing providers
We use various payment processing and payment gateway providers that facilitate connections with banks and payment systems globally. These providers enable a variety of payment methods and ensure efficient transaction processing. Examples include PayPal and Checkout.com. Each provider applies its own terms and privacy policy to the transactions it processes.

g. Communication service providers
Intercom provides messaging and customer support tools that enable communication within the Service. When you use in-App chat, certain data may be processed by Intercom on our behalf to identify you (if applicable) and facilitate communication. Intercom processes such data to deliver its services in accordance with its terms. Intercom complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”). Further information is available in its Privacy Policy.
We use Apple Push Notification service (“APNs”), a notification service provided by Apple, to send information to iOS devices.
We also use Firebase Cloud Messaging and Firebase Notifications, provided by Google, to send messages and notifications across platforms such as Android and iOS. These services may be integrated with Google Analytics to support audience analytics and event tracking (for example, identifying users who completed a training program and sending related messages). More information is available in Google’s Privacy Policy.
Additionally, we use OneSignal, a push notification service provider. When notifications are enabled, certain data is transferred to OneSignal to enable device identification, preference management, and effective communication. Further details are available in OneSignal’s Privacy Policy.

h. Marketing service providers
We use Meta Ads Manager and Meta Custom Audiences to display advertisements on Meta platforms (including Facebook and Instagram). This may involve creating audiences based on identifiers such as IDFA or user actions within the App (for example, installation or subscription purchase). As a result, you may be shown our advertisements while using Meta platforms. Information on managing advertising preferences is available within Meta’s settings.
We also use Google Ads, an advertising service provided by Google, which enables us to display targeted advertisements based on user interactions with our App (for example, subscription purchases or completion of workouts). Google also provides options to opt out of personalized advertising and restrict the use of data for such purposes.

We may process and disclose personal data to enforce our Terms and Conditions of Use, protect our rights, privacy, safety, or property (including those of our affiliates, users, or others), and to comply with requests from courts, law enforcement agencies, regulatory authorities, or other governmental bodies, where required by applicable law.

In the course of business development, we may acquire or sell assets or business units. Customer information is generally considered part of such transferred assets. We may also share data with affiliated entities and transfer information in connection with corporate transactions, including mergers, acquisitions, divestitures, or, in rare cases, insolvency proceedings.

We may share personal data with entities within our corporate group, including companies that we own, that own us, or that are under common ownership. Such entities process data in accordance with this Privacy Policy to ensure consistent protection of your personal information across our group of fitness and wellness services.

For the purpose of providing our services, we may share personal information with entities that perform services on our behalf or assist in fulfilling our business purposes. Depending on their role and relationship with us, such entities may be classified as service providers (or contractors) and third parties under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

To exercise control over your personal data, you are entitled to the following rights:

Access, review, update, and correction of your personal data.
You have the right to review, edit, or modify personal data you previously provided to us. If you wish to obtain a copy of the data we process, you may submit a data access request or, depending on the product you use, utilize a data access feature available within the profile section of the Service.

Deletion of your personal data.
You may request the deletion of your personal data to the extent permitted by applicable law. Upon receiving such a request, we will make reasonable efforts to comply. However, in certain cases, we may be legally required to retain specific data for a defined period (for example, records related to payments or requests submitted to us). In such cases, your request will be fulfilled with respect to the portion of data not subject to legal retention obligations, and the remaining data will be deleted once the applicable retention period has expired.

Information regarding data processing.
You have the right to be informed about the collection and use of your personal data. This includes the right to know what data is processed, for what purposes, with whom it is shared, and for how long it is stored. We aim to provide this information transparently within this Privacy Policy. If you require further details, you may contact us at any time.

Objection to or restriction of processing.
You may request that we stop or limit the processing of your personal data. For example:
• Email marketing: You may unsubscribe from marketing communications via the unsubscribe link included in each email or by contacting support.
• E-privacy settings: We provide privacy controls that allow you to manage tracking preferences on a granular, purpose-based level. These settings are typically available in the footer, menu, or profile section of our products.

Control over personalized advertising.
Depending on your device, you may manage advertising preferences as follows:
• iOS: Settings → Privacy → Advertising → Enable “Limit Ad Tracking.” You may also reset your advertising identifier in the same section.
• Android: Google Settings → Ads → Enable “Opt out of interest-based ads.” You may also reset your advertising identifier.Additional information on managing advertising preferences may be available through relevant platform resources and industry opt-out tools, including:
Network Advertising Initiative, Digital Advertising Alliance (US/Canada/EU), and AppChoices.We respect your right to control advertising preferences and provide information about the service providers involved in such processing.

Right to lodge a complaint.
You may contact us directly, as we prioritize resolving concerns promptly. However, you also have the right to file a complaint with a competent data protection authority.
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Right to data portability.
You may request to receive your personal data in a structured, commonly used, and machine-readable format (for example, a .json file).

You may request to receive your personal data in a structured, commonly used, and machine-readable format (for example, a .json file).

Verification of requests.
To process your request, we may need to verify your identity, typically by confirming that the request originates from the email associated with your account. In some cases, additional minimal verification may be required.

Authorized agents.
You may authorize another person to submit requests on your behalf. If valid authorization (such as a power of attorney) is provided, we will communicate directly with the authorized agent. Otherwise, we may contact you to confirm their authority.

If you reside in a U.S. state with applicable privacy legislation, you may have additional rights, including the ability to:
• opt out of the sale or sharing of personal data;
• opt out of targeted advertising or cross-context behavioral advertising.
We may share certain data with partners for advertising or analytics purposes, which may be considered “sale,” “sharing,” or “targeted advertising” under applicable laws. You may opt out of such processing.
We also aim to provide a “Your Privacy Choices” link within our products, typically located in the footer, menu, or profile section, depending on the service and device.

California residents may exercise additional rights under CCPA/CPRA, including:
• the right to know what personal data is collected, sold, or shared and to whom;
• the right to limit the use of sensitive personal data;
• the right not to be discriminated against for exercising privacy rights.
California residents may also request information under the “Shine the Light” law regarding disclosure of personal data for third-party marketing purposes.Requests may be submitted to taichi.help@proton.me.

If your privacy request is denied under applicable U.S. state laws, you have the right to appeal the decision within a reasonable timeframe. Appeals should be clearly marked as “PRIVACY APPEAL REQUEST FOR USA” and should include reference to the original decision for proper review.

We do not knowingly process personal data of individuals under 18 years of age. If you become aware that a person under the age of 18 has provided us with personal data, please contact us at{email}

We may transfer personal data to countries other than the country in which it was originally collected in order to provide the Service set out in the Terms and Conditions of Use and for the purposes described in this Privacy Policy. If such countries do not provide the same level of data protection as the country in which you initially provided the information, we implement appropriate safeguards, such as standard contractual clauses adopted by the European Commission.

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified via our Service or by other available means and will be given an opportunity to review the revised version. By continuing to access or use the Service after the changes become effective, you agree to be bound by the updated Privacy Policy.

We will retain your personal data for as long as it is reasonably necessary to fulfil the purposes set out in this Privacy Policy and our Terms and Conditions of Use (including providing the Service to you), which includes, without limitation, the period during which you maintain an account with the Service.We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. For example, under certain accounting and tax laws, we are required to retain Commercial Information for extended periods to comply with applicable legal requirements. Accordingly, even if you submit a data deletion request, a limited portion of data relating to our compliance obligations may be retained after such request has been fulfilled.

If you wish to send any notice under these Terms or have any questions regarding the Service and Products, you may contact us at: taichi.help@proton.me.