Privacy policy
Last updated OWNER: date of first publication
This policy covers the Primal Powerhouse coaching app and this website. It describes what we hold about you, why we hold it, and what you can do about it.
Coaching involves health data, which the GDPR treats as a special category requiring extra care. We have tried to write this plainly rather than defensively.
Who is responsible for your data
The data controller is OWNER: registered legal entity name, at OWNER: registered business address.
For anything in this policy — including access, correction and erasure — contact hello@primalpowerhouse.com.
OWNER: confirm whether a Data Protection Officer is required for your size and processing, and name them here if so
What we collect
Your account. Email address, name, timezone, and the password you sign in with (stored only as a hash, never as text we can read).
Your coaching profile. Phone number, date of birth, sex, height, current and goal weight, body fat percentage, waist measurement, activity levels, dietary restrictions and goals. These are what the training and nutrition calculations are built from.
What you record. Daily and weekly check-ins including how you rate your energy, hunger, sleep, nutrition and training; weigh-ins; progress photographs if you choose to add them; meals you select and mark as eaten; training sessions and the sets, reps and weights you log.
Your conversations. Messages between you and your coach, and the notes your coach keeps about your coaching.
We do not collect location data, we do not track you across other apps or websites, and we do not use advertising identifiers.
Why we hold it, and on what basis
Your account and profile exist to deliver the coaching you have signed up for — the legal basis is performance of a contract.
Health data — body metrics, check-ins, photographs — is special-category data under Article 9, and we rely on your explicit consent for it. You give that consent separately from agreeing to the terms, and you can withdraw it at any time from the Privacy screen in the app without giving a reason.
Progress photographs and marketing communications are each consented to separately again, so agreeing to one is never agreement to another.
Who can see it
Your coach can see your coaching record — that is the service. Nobody else's coach can: the app scopes every request to the signed-in person, and a coach cannot reach a client who is not theirs.
Platform administrators can see accounts and shared reference data such as the food and exercise libraries. They deliberately cannot read individual client records: check-ins, messages, photographs and body metrics are outside what an administrator can retrieve.
We do not sell your data and we do not share it with advertisers.
Where it is processed
The application and database run on servers in OWNER: hosting provider and country — e.g. Hetzner, Germany. Uploaded images are stored on OWNER: object storage provider and region and served over expiring signed links rather than public URLs.
OWNER: list any other processor that touches personal data — email delivery, error tracking, analytics — and note whether any transfer leaves the EEA
Meal generation, where your coach uses it, sends only ingredient names and quantities to a third-party model. It is not given your name, your account, or any of your body metrics.
How long we keep it
We keep your coaching record for as long as your account is open.
OWNER: confirm the retention period for records kept after an account closes, and any period your accountant or insurer requires you to keep billing records
Your rights
See and download everything. The Privacy screen in the app shows a count of everything held about you and exports the lot as JSON — a format any other app can read. You do not have to ask us for it.
Withdraw consent. Any of the separate consents can be switched off from the same screen, at any time, without a reason.
Delete your account. Also from that screen. Deletion is scheduled a fortnight ahead so you can change your mind, and your account works normally until then. You can cancel at any point before the date. Afterwards it is permanent.
When deletion happens we destroy your messages, coach notes, photographs, every body measurement, and the free text of your check-ins. Your account is closed and your email address is replaced with an unusable token so you cannot sign in again.
One thing survives: the record that coaching sessions and meals happened on given dates, with every identifying detail removed. That is your coach's record of work they performed, and a right to erasure of your own data is not a right to delete somebody else's business records.
Correct anything wrong. Most of it is editable in the app; for the rest, email us.
Complain. If you think we have handled your data badly you can complain to OWNER: your national supervisory authority. We would rather you told us first, but you do not have to.
Security
Traffic is encrypted in transit. On phones, the token that keeps you signed in is held in the device keychain and never leaves the device. On the web it is held only for the life of the browser tab, which is a weaker store — so web sessions end when you close the tab.
You can see every device currently signed in as you from the Privacy screen, and sign them all out at once.
Children
The service is not intended for children. Accounts are created by a coach after a conversation, and we do not knowingly coach anybody under OWNER: minimum age — 18 is the usual answer for calorie prescription.
Changes
If we change this policy in a way that matters we will tell you in the app rather than quietly updating the date at the top.