Privacy Policy

Effective Date: May 7, 2026

At Loosen ("we," "us," or "our"), your privacy is our top priority. We are dedicated to handling your personal data transparently, securely, and in full compliance with applicable laws. Given our initial launch focus in the European Union (EU), we prioritize the General Data Protection Regulation (GDPR) and UK GDPR for users in the European Economic Area (EEA) and UK. We also comply with the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA) for US users, and other relevant regulations worldwide. This Privacy Policy explains in clear, simple terms what data we collect, why we collect it, how we use and protect it, who we share it with, and your rights to control it.

We adhere to principles of privacy by design and data minimization—collecting only what's essential to deliver a personalized flexibility coach, track your progress, and improve the App. We do not track you across other apps or websites, do not use your data for advertising, and never sell or share your personal data for cross-context behavioral advertising (as defined under CCPA). The App does perform automated personalization (e.g. computing your daily Flexibility Score and recommending a session) — this is described in Section 3, has no legal or similarly significant effect on you, and you can opt out of the AI-powered parts at any time. If you have questions or need assistance exercising your rights, our team is available at hi@stretcha.co.

Summary

  • Data Collected: Account info (email or Apple/Google sign-in), self-reported profile and flexibility assessment, post-session feedback, in-app usage, and — only with your permission — read-only signals from Apple Health or Android Health Connect (e.g. steps, sleep, workouts, heart rate variability).
  • Uses: To compute your daily Flexibility Score, recommend a routine that fits today, adapt your plan based on signals and feedback, track progress, and send optional reminders.
  • Sharing: Limited to essential service providers (Supabase for storage, RevenueCat for subscriptions, Apple/Google for payments and authentication, PostHog for anonymous analytics, Anthropic for AI features when you consent) under strict contracts; no marketing shares.
  • AI is opt-in: No data leaves the device for our AI provider unless you explicitly accept the in-app AI consent prompt. You can revoke consent any time via Profile > AI & Data.
  • Your Rights: Access, update, export, or delete your data anytime via the App or email request—no fees or discrimination.
  • What We Don't Do: No location tracking, no access to camera/microphone/photos/contacts/calendar, no advertising profiling, no behavioral ad sales.
  • Health Focus: Health data is used only for personalization, progress, and safety; this is not medical advice—consult a professional.
  • Regional Focus: Primarily designed for EU users, with data processing optimized for GDPR compliance, while maintaining US (CCPA) and global standards.

By using the Loosen mobile application (the "App"), you consent to the practices outlined here. If you disagree, please do not use the App. We review and update this Policy at least annually or as needed to reflect changes in our practices, features, or laws. We will notify you of material changes via in-app notice or email.

1. Who We Are and Scope

We operate the Loosen App—a cross-platform mobile tool (iOS/Android) for guided stretching routines, progress tracking, and custom routine building, with an initial launch in the EU. This Policy applies to all personal data we process through the App. It does not cover third-party services linked from the App (e.g., external websites or payment processors' own policies).

Contact Us:
Email: hi@stretcha.co
Website: stretcha.co

For EEA/UK users, we act as the data controller under GDPR. For California residents, we are a "business" under CCPA/CPRA. We process data with EU users in mind first, using EU-based servers where possible to minimize transfers.

2. Personal Data We Collect

We collect only the minimum data required to provide, personalize, and improve the App. "Personal data" means any information relating to an identified or identifiable individual. We obtain your explicit consent for collecting sensitive data (e.g., health-related info) during onboarding, and you can withdraw it anytime. For EU users, we emphasize consent and legitimate interests as processing bases.

Account & Authentication

What: Email address and encrypted password, or — if you choose — the email address and provider-issued user identifier returned by Sign in with Apple or Sign in with Google. We never see your Apple/Google password.
Source: Provided by you during signup/login.
Why: To create and secure your account; enable login and session management.

Profile & Preferences

What: First name and last name, age band, experience level, goals (e.g. flexibility, pain relief, sleep), self-reported sitting hours and lifestyle, target areas, self-reported tight or painful areas (e.g. back, hips), self-reported health conditions, preferred session time, and notification preferences.
Source: Provided by you during onboarding or settings updates.
Why: To recommend a safe, personalized session and adapt your plan over time. Some of this is sensitive personal data (health information) under GDPR/CCPA; we process it on the basis of your explicit consent for personalization and safety filtering, and you can withdraw consent or delete this data at any time.

Flexibility Assessment

What: Per-area baseline scores (hips, hamstrings, shoulders, spine) and an overall starting Flexibility Score, derived from the onboarding self-assessment quiz. From there, these fields update automatically over time based on your session feedback, activity, and (if granted) Health/Health Connect signals.
Source: Self-reported answers you give during the in-app assessment.
Why: To anchor your daily Flexibility Score and tailor where each session focuses. Stored on your account in EU servers (for EEA/UK users).

Health & Activity Signals (Apple Health / Health Connect)

What: Read-only access to selected metrics: step count, active and basal energy burned, walking/running distance, flights climbed, heart rate, resting heart rate, heart rate variability, respiratory rate, blood oxygen, sleep stages, and workout sessions. We compute aggregates on your device (e.g. 7-day and 14-day averages of sedentary hours, sleep hours, and activity) and use those aggregates to drive the Flexibility Score and today's session recommendation.
Source: Apple HealthKit (iOS) or Android Health Connect, with your explicit OS-level permission. Read-only — we never write data back to Health.
Why: To answer the question your phone already knows the answer to: did you sit 11 hours today? Sleep 5? Run a 5k? — and recommend the right 8 minutes of stretching in response.
Where it lives: Raw Health samples stay on your device. Only the small numeric aggregates derived from them are sent to our servers (Supabase) so that the rest of the App can read them, and — only if you also accept AI consent — to our AI provider as part of the prompt context. You can revoke Health permission at any time in iOS Settings or the Health Connect app; without it, the App falls back to self-reported sitting hours and session feedback only.

Session Feedback

What: A short post-session response: how the session felt and which areas still feel tight.
Source: Tapped in by you at the end of each session.
Why: To adapt the next session — pose mix, duration, and which area to favor — to where your body actually is this week.

Usage & Progress

What: Session history (routines completed, duration, dates), streaks, total minutes stretched, and adaptive plan progress.
Source: Generated automatically from your App interactions.
Why: To display your progress, motivate you with streaks, and improve recommendations.

Device & Technical

What: Device model, OS version, app version, anonymous usage analytics (feature usage, session duration), and error reports via PostHog.
Source: Collected automatically via the App.
Why: To ensure compatibility, diagnose issues, optimize performance, and understand how features are used. PostHog generates an anonymous device ID for session tracking; we do NOT collect or link your name, email, user ID, or any personally identifiable information to analytics events. No cross-app tracking identifiers (e.g., IDFA) are collected.

Device Identifiers (via RevenueCat)

What: Device identifiers collected by RevenueCat SDK.
Source: Collected automatically when you use subscription features.
Why: To prevent subscription fraud, restore purchases across devices, and manage subscription access. Device identifiers are linked to your account to ensure purchases persist when you reinstall the app or switch devices.
Legal Basis: Necessary for contract performance (GDPR Article 6(1)(b)) - required to fulfill your subscription agreement.

Purchase History

What: Record of subscription purchases, active entitlements, and transaction history.
Source: Generated when you purchase or restore subscriptions.
Why: To manage your subscription access, handle renewals, and enable purchase restoration.
Provider: RevenueCat (third-party subscription platform).

AI Features (Optional, Consent-Gated)

What: When — and only when — you accept the in-app AI consent prompt, parts of the data above are sent to our AI provider (Anthropic) so that an AI feature can run. Different AI features send different subsets; the full mapping is in Section 3 ("AI-Powered Features").
Source: Already collected on the basis of the categories above; transmission to the AI provider only happens after explicit AI consent.
Why: To power the four optional AI features: Build with AI (chat-driven custom routines), the adaptive plan generator (which rebuilds the next session based on your signals and feedback), the body-state explanation on the home screen, and the personalized plan narrative.
Revocation: Withdraw consent any time via Profile > AI & Data. After revocation no further data is sent to Anthropic, and the App falls back to non-AI templates and static copy.

What We Do NOT Collect

  • • Location data (precise or coarse)
  • • Access to camera, microphone, photos, contacts, calendar, or motion sensors
  • • Health data beyond the read-only metrics listed above (we never write to Apple Health or Health Connect)
  • • Any data for cross-app tracking, behavioral advertising, or advertising profiling
  • • Children's data (App is for 13+; see Section 7)

3. How We Use Your Personal Data

We process data only for specific, legitimate purposes, with your consent where required (e.g., for sensitive health data). We follow data minimization and pseudonymization where possible, with special attention to EU users under GDPR.

  • Personalization & Safety: Use profile, assessment, feedback, and (if granted) Health/Health Connect signals to compute your daily Flexibility Score, recommend a session that fits today, filter poses for safety (e.g. avoid back strains if reported), and adapt your plan over time.
  • Subscription Management: Track active subscriptions, process entitlements, enable premium features, and restore purchases across devices via RevenueCat. Legal basis: Contract performance (GDPR Article 6(1)(b)).
  • Progress & Motivation: Track sessions to show streaks, totals, and achievements in-app.
  • Communications: Send optional push notifications (e.g., daily reminders at your preferred time) or emails (e.g., password resets).
  • Operations & Improvements: Analyze anonymous usage patterns via PostHog to fix bugs, enhance features, and improve app performance. PostHog auto-generates anonymous device IDs for session tracking; no identifiable user data is processed for analytics. We do not use your data for advertising profiling or to build cross-app behavioral profiles. Legal basis: Legitimate interest (GDPR Article 6(1)(f)).
  • Legal Compliance: Retain data as required by law (e.g., for audits); delete upon request.

Automated Personalization

The App computes results automatically — your Flexibility Score, the daily session pick, and (if you have accepted AI consent) AI-generated routines and plan narratives. These outputs personalize your in-app experience. They are not used to grant or deny access to any service, set pricing, or produce any legal or similarly significant effect on you under GDPR Article 22. You can:

  • Override the daily pick by choosing a different routine from the catalog or by building one yourself.
  • Withdraw AI consent in Profile > AI & Data, which silently switches the App to non-AI templates and static copy.
  • Revoke Health permission in iOS Settings or Health Connect, which removes those signals from the calculation.
  • Contact hi@stretcha.co to ask how a specific recommendation was produced or to request human review.

Legal Bases (GDPR/UK GDPR): Consent for sensitive data; legitimate interests for core features (e.g., progress tracking); contract performance for account services. For US users, we align with CCPA requirements.

Data Retention: We keep data only as long as needed—account data until deletion; progress data for 2 years after last activity (or sooner if requested). Anonymized aggregates may be retained longer for improvements.

AI-Powered Features

The App uses Anthropic's Claude AI model (via secure server-side processing through Supabase Edge Functions) to power four optional AI features. All processing happens on our servers — no AI runs on your device.

Consent (hard gate, defense in depth): Before any data is sent to Anthropic for any of these features, you are presented with an in-app consent prompt that clearly identifies what data will be shared, who it will be shared with, and requires your explicit approval. The consent state is stored on your account (plan_ai_consent) and checked both on the device and again on our servers as the first operation of every AI call — if consent is not present, the call is rejected before any prompt is constructed, and the App falls back to non-AI templates and static copy. You can revoke this consent at any time via Profile > AI & Data; revocation takes effect immediately across all four features.

The four AI features and the data each one sends:

1. Build with AI (chat-driven custom routines)

Sent to Anthropic: your chat messages and your profile preferences (experience level, reach flexibility, lifestyle, goals, self-reported health conditions, preferred session time). Health/Health Connect signals are not sent for this feature.

2. Adaptive Plan Generator

Sent to Anthropic: profile fields (problem areas, pain areas, stretching history, goals, health conditions, preferred session time), your last few session-feedback rows, your per-area Flexibility Scores and recent deltas, and — if you granted Health/Health Connect access — 14-day rolling averages of sedentary hours, sleep hours, and active hours plus 7-vs-14-day trends. Used to silently rebuild the next session in your plan.

3. Body-State Explanation (home screen)

Sent to Anthropic: today's body-state archetype (e.g. "sedentary slump"), the recommended routine's name, duration, and target areas, and a small set of derived signals (e.g. yesterday's sedentary hours bucket). Used to write the one-sentence reasoning under today's pick.

4. Plan Narrative

Sent to Anthropic: profile fields (age band, lifestyle, experience level, goals, target areas, problem/pain areas, health conditions, self-reported sitting hours), your overall and per-area Flexibility Scores, and — if you granted Health/Health Connect access — 7-day averages of sedentary hours and sleep hours plus recent workout types. Used to write the personalized "where you are / what we'll work on" narrative on your plan screen.

What is never sent: account identifiers (email, password, Apple/Google sign-in tokens) are never sent to Anthropic; raw HealthKit / Health Connect samples (individual heart-rate readings, sleep records, etc.) are never sent — only the small derived aggregates listed above. Data is processed in real time and is not stored by Anthropic after the response is generated. Your data is never used to train any AI models. For details, see Anthropic's privacy policy.

4. Sharing and Disclosure

We share data minimally, only with vetted providers under strict data processing agreements ensuring equivalent protection. For EU users, we prioritize EU-based processing to comply with GDPR data transfer rules.

  • Supabase: EU servers for EEA/UK users (to avoid transfers); handles storage, auth, and real-time sync. US servers for non-EU users.
  • RevenueCat: Manages subscriptions and in-app purchases. Collects and links device identifiers to your user account for fraud prevention, purchase restoration, and subscription management. Processes user IDs (anonymous UUIDs) to associate purchases with accounts. No payment card details are stored by us or RevenueCat.
  • User IDs: User IDs (anonymous UUIDs) are shared with RevenueCat to link subscriptions to your account, enabling purchase restoration and cross-device access.
  • Apple/Google: For in-app purchases and push notifications (they process device tokens).
  • PostHog: Manages anonymous product analytics and error tracking; processes usage events, device metadata, and crash logs. Hosted in the EU (https://eu.i.posthog.com) for GDPR compliance. No identifiable user data (name, email, user ID) is shared—only anonymous device IDs auto-generated by PostHog for session tracking. Standard Contractual Clauses apply.
  • Anthropic: Processes the data described in Section 3 ("AI-Powered Features") via the Claude AI model to power our four AI features (Build with AI, the adaptive plan generator, the body-state explanation, and the plan narrative). Data is sent only after you provide explicit in-app consent (plan_ai_consent = accepted) and only as long as that consent is active. Anthropic does not use your data to train their models. Anthropic is bound by their published privacy policy and our data processing terms, which require equivalent protection of user data, prohibit independent use of the data, and prohibit use for model training.
  • Apple HealthKit / Android Health Connect: Not third parties in the data-sharing sense — these are platform APIs on your own device. You grant the App read-only permission and we read the metrics described in Section 2. Apple and Google do not receive any new data from us via these APIs.

International Transfers (GDPR): Data for EU users stays in the EU where possible. For transfers (e.g., to US providers), we use Standard Contractual Clauses or equivalent safeguards. We do not share with governments except as legally required (e.g., valid subpoena).

No sales or marketing shares: We do not sell, rent, or share data for advertising/marketing. Under CCPA, "sale" or "sharing" does not occur.

5. Data Security and Integrity

We implement industry-standard measures tailored to data sensitivity, especially health info, with GDPR-compliant risk assessments:

  • Encryption: Data in transit (TLS 1.3+) and at rest; passwords hashed with strong algorithms.
  • Access Controls: Role-based; multi-factor auth for staff; no unnecessary access.
  • Security Practices: Regular vulnerability scans, penetration testing, and incident response plans. Annual independent audits.
  • Breach Response: Notify affected users and authorities promptly if required (e.g., within 72 hours under GDPR).

6. Your Privacy Rights and Choices

You have full control—exercise rights without fees, discrimination, or verification delays (we verify via email). EU users benefit from enhanced GDPR rights.

  • Access/Portability: View/export data in-app (Settings > Profile > Export Data) or request via hi@stretcha.co (response within 30 days; 15 under CCPA). Includes historical data back to account creation (per CCPA 2026 updates).
  • Update/Rectify: Edit profile/health info directly in-app.
  • Delete/Erasure ("Right to Be Forgotten"): Delete account via Settings > Delete Account—erases all personal data within 30 days (retention for legal reasons noted).
  • Opt-Out/Withdraw Consent: Disable reminders/notifications in settings; revoke health data consent (resets personalization). No "Do Not Sell/Share" needed as we don't sell/share. Honor Global Privacy Control (GPC) signals.
  • AI Data Consent: You can revoke consent for AI data processing at any time via Profile > AI & Data. Revocation takes effect immediately across all four AI features, both client-side (no further calls are dispatched) and server-side (any incoming calls are rejected before any prompt is constructed). The App falls back to non-AI templates and static copy until you re-consent.
  • Health Permission: Revoke Apple Health (iOS) or Android Health Connect access at any time in your OS settings. The App will continue to work using your self-reported sitting hours and session feedback only.
  • Sensitive Data: Explicit opt-in for health data; limit processing via settings.
  • Appeals: If we deny a request, appeal via hi@stretcha.co—we review promptly.
  • Opt-Out of Analytics: PostHog uses fully anonymous analytics (no identifiable data). Since no personal information is tracked, no opt-out mechanism is required under GDPR/CCPA. If you have concerns, contact hi@stretcha.co.

For CCPA: Designated agent for requests: hi@stretcha.co. We disclose metrics annually (e.g., requests received/fulfilled).

7. Children's Privacy

The App is intended for users 13+ (16+ in EEA for consent without parental involvement). We do not knowingly collect data from children under 13 (or 16 in EEA). If we discover such data, we delete it immediately. Parents/guardians: Contact hi@stretcha.co for inquiries or deletion requests.

8. Medical and Health Disclaimer

Loosen is a wellness tool, not a medical device, diagnostic service, or substitute for professional advice. Self-reported health data is used solely to personalize routines and avoid potential risks—it's not verified or intended as medical guidance. Always consult a healthcare provider before starting any exercise program, especially if you have medical conditions. We disclaim all liability for injuries or health issues arising from App use—participate at your own risk.

9. Changes to This Policy

We may update this Policy to reflect new features, legal changes, or practices. Material changes (e.g., new data uses) will be notified via in-app banner or email at least 30 days in advance, with your continued use constituting acceptance. Check back regularly.

10. Contact and Complaints

For questions, rights requests, or complaints: hi@stretcha.co (response within 30 days; 15 under CCPA). If unresolved, contact your local data protection authority (e.g., your national DPA in the EU, ICO in UK, CPPA in California) or file a complaint.

Thank you for trusting Loosen. We're committed to your privacy—empowering your flexibility journey securely, starting in the EU.