Privacy Policy

1. Who We Are

This Privacy Policy applies to the PocketPT mobile application ("App"), the Frankie AI coaching service, and the website at frankieapp.ai (collectively, "Services"), operated by POCKET PT LTD, a company registered in the United Kingdom.

Data Controller: POCKET PT LTD
Contact: hello@frankieapp.ai

2. Data We Collect

We collect information you provide directly and data generated through your use of the App.

Account & Profile Data

• Name and email address
• Date of birth and gender
• Height, weight, and body composition goals
• Fitness level, training history, and health conditions (where disclosed)

Health & Activity Data

• Workout logs, exercise performance, and training plans
• Nutrition logs (food entries via text, photo, or voice)
• Heart rate, HRV, sleep, and activity data (via Apple Health / Google Fit, with your permission)
• Readiness and recovery scores
• Assessment results

Usage & Technical Data

• App usage patterns and feature interactions
• Device type, operating system, and app version
• Crash reports and performance diagnostics
• IP address and approximate location (country/region)

Communications

• Messages and conversations with the Frankie AI coach
• Support requests and feedback you submit
• Waitlist email addresses collected on our website

3. How We Use Your Data

We use your data to:

• Provide, personalise, and improve your coaching experience
• Generate personalised training programmes and nutrition guidance
• Calculate readiness scores and adaptive recommendations
• Operate the Frankie AI coach and respond to your queries
• Send app updates, new features, and service notifications
• Detect and prevent fraud, abuse, and security incidents
• Comply with legal obligations
• Conduct anonymised research to improve the App

We will only use your data for purposes compatible with those listed above. We will notify you before using your data for any materially different purpose.

4. Legal Basis for Processing (UK / EU Users)

Where GDPR or UK GDPR applies, we process your data on the following legal bases:

• Contract performance — to deliver the App and coaching services you signed up for
• Legitimate interests — to improve our services, prevent fraud, and ensure security
• Consent — for health data processing, marketing communications, and optional integrations
• Legal obligation — where required by applicable law

For health and fitness data (a special category under GDPR), we rely on your explicit consent, which you can withdraw at any time.

5. Data Storage & Security

Your data is stored on servers provided by Supabase (PostgreSQL database), hosted on infrastructure within the European Economic Area or UK. We use industry-standard security practices including:

• Encryption at rest and in transit (TLS 1.2+)
• Access controls and authentication requirements
• Regular security reviews
• Minimal data retention — we keep your data only as long as needed to provide the Services or as required by law

While we take all reasonable steps to protect your data, no internet transmission is 100% secure. Please contact us immediately at hello@frankieapp.ai if you suspect any unauthorised access to your account.

6. Third-Party Services

We use trusted third-party providers to operate our Services. Each processes your data only as necessary for their specific function:

• Supabase — database and authentication infrastructure
• OpenAI — powers the Frankie AI coaching conversations (your messages may be processed by OpenAI's API under their data processing terms; we do not permit OpenAI to train on your data)
• ElevenLabs — AI voice synthesis for audio coaching features
• Apple HealthKit / Google Fit — optional health data integration (requires your explicit permission)
• GIPHY — GIF content within the app (non-personal usage data only)
• Analytics — anonymised, aggregated usage analytics to improve the App

We do not sell, rent, or trade your personal data to any third party. We require all service providers to maintain appropriate data protection standards under binding agreements.

7. Your Rights

Depending on your location, you have the following rights regarding your personal data:

• Access — request a copy of the personal data we hold about you
• Rectification — ask us to correct inaccurate or incomplete data
• Erasure — request deletion of your personal data ("right to be forgotten")
• Restriction — ask us to limit how we process your data in certain circumstances
• Portability — receive your data in a structured, machine-readable format
• Objection — object to processing based on legitimate interests
• Withdraw consent — withdraw consent at any time where processing relies on consent
• Complaint — lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk

To exercise any of these rights, email us at hello@frankieapp.ai. We will respond within 30 days.

8. Children's Privacy

PocketPT is not intended for users under the age of 16. We do not knowingly collect personal data from children under 16. If you believe we have inadvertently collected data from a child, please contact us immediately and we will delete it.

9. Cookies & Tracking

Our website (frankieapp.ai) may use cookies and similar technologies for:

• Essential site functionality
• Anonymous analytics to understand how visitors use the site

We do not use advertising or cross-site tracking cookies. You can control cookies through your browser settings.

10. Data Retention

We retain your personal data for as long as your account is active or as needed to provide the Services. You may request account deletion at any time. Upon deletion:

• Your personal data is deleted within 30 days
• Anonymised, aggregated data may be retained for research purposes
• Data required by law (e.g. financial records) will be retained for the legally required period

11. International Transfers

Your data is primarily stored in the UK / EEA. Where data is transferred outside of these regions (for example, to OpenAI servers in the US), we ensure appropriate safeguards are in place, including standard contractual clauses approved by the UK ICO or European Commission.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via the App or by email. Continued use of the Services after the effective date of any changes constitutes acceptance of the updated policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

POCKET PT LTD
Email: hello@frankieapp.ai
Website: frankieapp.ai