Privacy Policy

Effective from: 6 October 2026

This Privacy Policy explains how Proge processes the personal data of its users.

It applies to the Proge mobile application and related services, including the user account, training features, nutrition and weight tracking features for adult users, and AI Coach.

Controller and contact details

The controller responsible for processing Proge users’ personal data is:

IceDev Oy

Business ID: 3658202-2

Finland

Contact:

info@proge.app

Users may contact IceDev Oy at the address above in privacy-related matters.

No data protection officer has currently been appointed.

Age requirements and younger users

The minimum age for using Proge is 16 years.

Proge processes personal data relating to:

• users aged 18 or over; and
• users aged 16–17 in connection with the features available to them.

Users aged 16–17 are not provided with:

• nutrition features;
• weight tracking; or
• AI Coach personalisation that uses health data.

Users under the age of 16 may not use Proge.

Personal data processed

The personal data processed depends on which Proge features the user uses.

Proge may process, for example:

• service-specific technical user identifier;
• identity information related to Google sign-in;
• basic information received from the user’s Google account for authentication purposes;
• user account status;
• technical information related to authentication and sign-in.

Authentication information

Google sign-in is used to authenticate the user.

Proge does not request access through Google sign-in to the user’s Gmail messages, contacts, or Google Drive content.

Proge may process, for example:

• name or username;
• age;
• sex;
• height;
• weight and target weight for users aged 18 or over;
• training location;
• primary training goal;
• experience level;
• training frequency;
• training preferences;
• available equipment;
• activity level;
• user-reported amount of sleep;
• language;
• measurement units;
• other coaching settings selected by the user.

Proge may process, for example:

• training programmes;
• exercises;
• sets;
• repetitions;
• weights used;
• workout duration;
• RPE data;
• workout completion status;
• unfinished workouts;
• workout history;
• running distances;
• running pace;
• training or running feedback provided by the user.

Nutrition and weight tracking features are available only to users aged 18 or over.

Proge may process, for example:

• current weight;
• target weight;
• nutrition approach;
• activity-related information;
• diet type;
• number of meals;
• food selections;
• food quantities;
• changes made by the user to food quantities;
• meals marked as eaten;
• calorie amounts;
• protein;
• carbohydrates;
• fat;
• fibre;
• calculated information required to generate the user’s nutrition plan.

Measurement and progress data

Users may store measurement data relating to their own progress in Proge.

This may include the measurement value and date, as well as other information required to provide the relevant feature.

Weight-related measurement data is processed only in features intended for users aged 18 or over.

Weight, nutrition, training, or measurement data is not automatically health data within the meaning of Article 9 of the GDPR. However, depending on its content and context, such data may constitute health data.

AI Coach data

When a user uses AI Coach, Proge may process, for example:

• the user’s message;
• the AI Coach response;
• limited recent conversation history;
• profile information necessary for the question;
• training preferences;
• active training programmes;
• workout history;
• nutrition data of users aged 18 or over where necessary for the question;
• permitted measurement data;
• technical usage information relating to the AI request;
• information required to enforce usage limits.

The Proge context used to process a question is assembled according to the request. Not all information stored about the user is automatically sent to the AI service.

Health information provided to AI Coach

A user aged 18 or over may voluntarily provide AI Coach with information concerning their health, such as information about:

• pain;
• injury;
• illness;
• previous surgery; or
• another health-related matter.

Such information may constitute health data within the meaning of Article 9 of the GDPR.

Processing such information in AI Coach requires the user’s separate explicit consent.

Consent is voluntary and is not required for other use of Proge.

Health-data-based AI Coach personalisation is not offered to users aged 16–17.

Sources of personal data

Proge obtains personal data primarily:

• directly from the user;
• from choices and actions made by the user in the application;
• through Google sign-in for authentication purposes;
• from the user’s recorded activity and performance;
• from calculations and programme generators based on information supplied by the user;
• from technical use of the service.

In its current implementation, Proge does not retrieve users’ health data from Apple Health, Health Connect, medical records, or other external health data sources.

Purposes of processing

Proge processes personal data for the following purposes.

To authenticate the user, enable sign-in, and maintain user-specific data.

To adapt training and other available features based on information and choices provided by the user.

To generate programmes based on the user’s goals, experience, training environment, training frequency, available equipment, and other selections.

To store completed activities, implement progression logic, and display the user’s training and progress history.

Nutrition and weight tracking features are available only to users aged 18 or over.

To provide nutrition plans requested by the user, track nutrition, allow food substitutions and changes, and perform calculations relating to weight and nutrition goals.

To respond to user questions and personalise responses using Proge context that is necessary for the question.

For example:

• enforcing usage limits;
• protecting user accounts and backend systems;
• preventing unauthorised use;
• investigating technical errors;
• investigating security or abuse incidents.

For example, handling data subject rights requests and responding to lawful requests from authorities.

Legal bases for processing

This is generally the legal basis for processing necessary to provide Proge features requested by the user, including:

• user account and authentication;
• profile and coaching settings;
• generation of training programmes;
• workout history and progression tracking;
• nutrition features requested by users aged 18 or over;
• ordinary AI Coach coaching functionality.

Proge may process necessary technical data, for example, to:

• maintain service security;
• prevent misuse;
• maintain technical reliability;
• establish, exercise, or defend legal claims.

Proge’s legitimate interests in these cases are protecting the service, its users, and personal data, as well as maintaining the safe operation of the service.

Personal data may be processed where Proge is required to comply with a legal obligation, such as handling a data protection rights request or complying with a lawful authority request.

Where processing is based on consent, the user will be informed of this separately.

Processing health information voluntarily provided to AI Coach is based on separate explicit consent.

Consent may be withdrawn at any time.

Withdrawal does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

The minimum age for using Proge is 16.

Users aged 16–17 are provided with a restricted set of features.

Proge does not collect through the relevant restricted features:

• nutrition feature data;
• weight tracking data; or
• health data for AI Coach personalisation.

Proge uses the age reported by the user to restrict access to features.

Automated processing

Proge automatically generates personalised training programmes and other service content based on information and choices provided by the user.

This automation is used to provide Proge’s coaching features.

In its current implementation, Proge does not make decisions based solely on automated processing that produce legal effects concerning the user or similarly significantly affect the user within the meaning of Article 22 of the GDPR.

AI Coach automatically generates responses to user questions. The user is informed within the service that AI Coach is an AI-based feature.

Local storage

Proge uses user-scoped local storage.

The device may store, for example:

• local user data required for application functionality;
• user-specific settings;
• training data;
• limited AI Coach conversation history;
• local notification settings;
• streak data.

Local data is separated on a per-user basis within the application.

Google and Firebase

Proge uses Google/Firebase services for purposes including:

• user authentication;
• storing user-specific cloud data;
• data synchronisation;
• backend functionality;
• protecting backend resources.

Cloud Firestore may contain, for example, profile, training, nutrition, measurement, consent, and technical AI request data.

Proge does not claim in this Privacy Policy that all Firebase processing takes place in Finland or within the EEA.

Google states that Firebase Authentication operates from data centres in the United States and processes Authentication data in the United States.

OpenAI and AI Coach

Proge uses the OpenAI API to generate AI Coach responses.

Only content and Proge context necessary for processing the AI Coach request are sent to OpenAI.

Google/Firebase provides Proge with authentication, database, backend, and security infrastructure, among other services.

Google processes Proge Customer Data on Proge’s behalf in situations where Google acts as a processor under the applicable service terms.

Google may also process certain service and security information for its own service management purposes under the applicable terms.

The OpenAI API is used to generate AI Coach responses.

Depending on the question, the content sent to AI Coach may include, for example:

• the user’s message;
• limited conversation history;
• necessary profile context;
• training information;
• active programme information;
• workout history;
• nutrition information of users aged 18 or over where necessary for the question;
• health information only where valid explicit consent is in force.

Proge uses the store: false setting in the OpenAI API.

OpenAI states that data submitted to its API is not used to train its models by default unless the customer explicitly chooses to share data for that purpose.

Proge has not enabled voluntary sharing of user data for OpenAI model training.

Disclosure of personal data

Where necessary, personal data may also be disclosed to:

• a competent authority where required by law;
• legal or other professional advisers where necessary for handling a legal matter and subject to appropriate confidentiality.

Proge does not sell users’ personal data.

Proge does not use user data for third-party targeted advertising.

International data transfers

Google/Firebase and OpenAI operate internationally.

For this reason, Proge personal data may also be processed outside the European Union and European Economic Area.

Where personal data is transferred outside the EEA, the transfer is based, as applicable, on a mechanism permitted under Chapter V of the GDPR, such as:

• an adequacy decision of the European Commission;
• the EU–US Data Privacy Framework where applicable;
• Standard Contractual Clauses adopted by the European Commission;
• another transfer mechanism permitted under the GDPR.

The applicable data processing terms of Proge’s service providers include arrangements relating to international transfers.

Google Play subscriptions and payment data

On Android, Proge Premium subscriptions are purchased through Google Play. Google Play processes payments and the necessary payment details under its own privacy practices. IceDev Oy does not need the full payment card number or security code to verify a subscription.

To verify subscriptions, manage access, provide support and prevent abuse, Proge may process:

• the technical Proge account identifier;
• a pseudonymised billing identifier linked to the account;
• a hash derived from a purchase token;
• product, base plan and offer identifiers;
• subscription status, expiry and automatic renewal status;
• a Google Play subscription order identifier;
• verification, update, cancellation and refund information.

This information is linked to the Proge account to assign access to the correct user. Processing necessary to perform the contract relies on Article 6(1)(b) GDPR. Necessary security, anti-abuse and legal-claims processing may rely on legitimate interests under Article 6(1)(f). Processing required by law relies on Article 6(1)(c).

Google Play and related Google services process subscription information under their applicable terms and privacy practices. Proge uses Google Play APIs to verify subscriptions and update entitlements. IceDev Oy does not sell subscription or payment data or use it for third-party targeted advertising.

Subscription data retention

Proge retains subscription and entitlement data only for as long as necessary for their purposes or as required by law. When an account is deleted, operational subscription and entitlement records linked to that account are removed under the account-deletion procedure.

An irreversible purchase-token hash and deletion timestamp may be retained as limited technical information to prevent unauthorised reuse of the same purchase. Any accounting or other records that must be retained by law are handled separately to the extent necessary.

Deleting a Proge account does not automatically cancel a Google Play subscription. Google Play's own retention of payment data is governed by Google's practices.

AI Coach data retention

Proge’s own AI Coach conversation history and any retention within OpenAI’s API systems are separate matters.

Limited AI Coach conversation history is stored on the user’s device on a user-specific basis.

The history expires after 12 hours of inactivity.

Expired history is not used as context for a subsequent AI Coach conversation and is removed from Proge’s conversation memory.

OpenAI states that API inputs and outputs may, subject to applicable exceptions, be retained securely for up to 30 days for purposes including service provision and abuse monitoring, unless longer retention is required by law.

Proge’s use of store: false does not mean that Proge has a Zero Data Retention arrangement with OpenAI.

Proge may store technical metadata concerning AI Coach requests, such as:

• request ID;
• request time;
• status;
• model used;
• policy version;
• token counts;
• latency;
• error or safety classification.

The user’s actual AI Coach message or AI Coach response is not normally stored in this technical metadata.

Personally linkable technical AI request metadata is normally retained for 90 days. After that, the metadata is deleted through Firestore’s managed TTL process.

Data may exceptionally be retained for longer where necessary, for example, for an ongoing security investigation, abuse incident, or legal claim.

Retention periods

Proge retains personal data only for as long as it is necessary for the relevant purpose of processing or where another valid legal basis requires retention.

The main retention principles are:

• user account and related authentication data: for the lifetime of the user account;
• profile and onboarding data: for the lifetime of the account or until replaced;
• training programmes and workout history: generally for the lifetime of the account for as long as required to provide progression and historical features;
• nutrition data: generally for the lifetime of the account or until replaced or deleted;
• weight and measurement data: generally for the lifetime of the account;
• local AI Coach conversation history: 12 hours after the last activity;
• Proge technical AI request metadata: 90 days;
• AI Coach quota data: only for as long as needed to calculate usage limits;
• Terms acceptance records: for the lifetime of the account and, where necessary, for a limited period afterwards to demonstrate acceptance;
• health data consent evidence: for as long as reasonably necessary to demonstrate the lawfulness of earlier processing;
• records relating to privacy requests and security incidents: for as long as necessary to comply with legal obligations or address legal claims.

When personal data is no longer required, it is appropriately deleted or anonymised.

Health data consent and withdrawal

A user aged 18 or over may provide separate explicit consent to the processing of health data in AI Coach.

Providing consent:

• is voluntary;
• is not a condition for other use of Proge;
• may be withdrawn at any time.

When consent is withdrawn:

• the consent status is changed to withdrawn;
• new health data is no longer used for health-data-based AI Coach personalisation;
• previous health-related conversation context is not used in new AI requests;
• the user’s local AI Coach conversation history is cleared.

Proge may retain limited evidence that consent was previously given and later withdrawn where necessary to demonstrate the lawfulness of earlier processing.

Consent evidence does not contain the health information itself merely for the purpose of proving consent.

Local notifications

Proge’s current reminders and notifications are local notifications.

Settings such as notification times and weekdays are stored on the user’s device.

In the current implementation, these local notification settings are not stored in Proge’s cloud systems.

Data security

Proge uses technical and organisational measures to protect personal data.

These include, for example:

• Firebase Authentication;
• encrypted network connections;
• access control tied to user identity;
• separation of user-specific data;
• backend validation;
• Firestore security rules;
• Firebase App Check;
• user-scoped local storage;
• restriction of AI Coach context;
• age-based feature restrictions;
• usage limits and misuse prevention.

No information system can, however, be completely immune from technical faults or security threats.

Account and data deletion

Users can initiate deletion of their Proge account from within the application.

The deletion process is intended to remove:

• the user’s Firestore user tree and its subdata;
• the Firebase Authentication user;
• user-specific local Proge data;
• local AI Coach conversation history;
• user-specific local settings;
• notification settings;
• local streak data.

If a user can no longer access the application, deletion of the account and associated data may also be requested through the deletion channel provided on the Proge website.

Deleting the Proge application from a device is not the same as deleting the Proge account. Cloud data and the user account may continue to exist after the application has been removed.

After account deletion, limited data may be retained only where there is a separate legal basis, for example:

• a legal obligation;
• establishment, exercise, or defence of a legal claim;
• demonstrating previous consent or acceptance of Terms;
• documenting a security incident;
• a service provider’s normal backup cycle;
• a service provider’s own lawful retention obligations.

Such data is not used to continue the normal user account or for marketing purposes.

Data subject rights

Depending on the applicable processing and its legal basis, the user may have the right to:

• receive information about the processing of their personal data;
• access their personal data;
• request correction of inaccurate personal data;
• request deletion of personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• receive certain personal data they provided in a portable format where the conditions for data portability are met;
• withdraw consent at any time;
• lodge a complaint with a competent data protection authority.

The applicability of each right depends on the relevant processing and legal basis.

Privacy-related requests may be sent to:

info@proge.app

Proge may request reasonable additional information where necessary to verify the identity of the person making the request before acting on a request concerning personal data.

Right to lodge a complaint

If a user believes that their personal data has been processed in violation of applicable data protection law, they have the right to lodge a complaint with a competent supervisory authority.

In Finland, the supervisory authority is the Office of the Data Protection Ombudsman.

Changes to this Privacy Policy

Proge may update this Privacy Policy, for example, where:

• service features change;
• personal data processing changes;
• a new service provider is introduced;
• legislation or regulatory guidance changes.

If a change materially affects the processing of the user’s personal data, appropriate information will be provided to the user.

Reading this Privacy Policy or acknowledging that it has been read does not constitute general consent to the processing of personal data.

Where processing requires consent, consent will be requested separately.

Contact

For questions concerning privacy, personal data, or data subject rights:

IceDev Oy

Business ID: 3658202-2

Finland

info@proge.app