Privacy
Privacy Policy
DRAFT — legal content pending review before publication. Fields marked [TO COMPLETE] still need to be filled in.
This policy explains what data TWAINING processes, why, who it is shared with, and how you stay in control. It covers the TWAINING iOS app, the connection between TWAINING and your AI assistant (ChatGPT or Claude), and the twaining.app website.
The short version
- Your data is used to run TWAINING. No ads, no data sales, no ad trackers.
- Your assistant only gets your data if you connect it, and you can disconnect it from the app at any time.
- From the app, you can view and edit your profile, turn off sleep sharing and delete your account.
1. Who we are
TWAINING, a French simplified joint-stock company (société par actions simplifiée) with share capital of [TO COMPLETE: share capital], registered with the Paris Trade and Companies Register under number 131 920 787, with its registered office at 138 avenue Victor Hugo, 75116 Paris, France (“TWAINING”, “we”, “us”).
Questions about your data: contact@twaining.app.
2. Data we process
| Data | Details | Why |
|---|---|---|
| Account | What Sign in with Apple provides: an anonymous identifier, your email address (or Apple’s relay address if you choose to hide it), whether Apple verified it, your first and last name if you choose to share them, and, from the app, Apple’s indication that the account likely belongs to a real person. The same information whether the account is created in the app or on twaining.app, except that indication, which Apple only gives in the app. | Create your account, sign you back in and email you about your account and TWAINING |
| Training | Programs, sessions, exercises, sets, weights, durations, how it felt, notes, history. | Guide your sessions and keep your history |
| Running | Precise location during a run (GPS route), distance, pace, cadence. | Measure and record your runs |
| Apple Health | Daily steps and sleep duration, read on your iPhone. Nights are only sent to TWAINING while sleep sharing is on. TWAINING does not write workouts to Health. | Track your step goal, reminders and recovery |
| Body profile | Sex, age, height and weight, all optional, entered at sign-up, in the app or through your assistant. | Tailor your sessions and track your progress |
| Coaching profile | Goals, equipment, habits, constraints, check-ins, weight goal, and a history of changes. | Give your assistant context from one conversation to the next |
| Connections | Connected assistants, connection and last-use dates, access tokens (stored hashed). | Authorize, monitor and revoke your assistant’s access |
| App usage | Screens opened, sign-up steps, assistant connection, how workouts unfold (start, end, pauses, skipped rests), syncs, with the app and iOS versions, your App Store country and an install identifier. Never your comments, loads, measurements or location. | Understanding how the app is used and improving it |
| Technical logs | Your assistant’s calls to TWAINING (tool used, result, duration) and problem reports your assistant sends. | Security, troubleshooting and bug fixes |
| Subscription | Your subscription status. Payment is handled by Apple, or by Stripe for a subscription purchased on twaining.app: we never receive your card details. For a web subscription, Stripe sends us a customer ID; your email, billing address and invoices stay with Stripe. | Unlock paid features |
Steps, sleep, your body profile and location are sensitive data. Apple Health data and location are only read after you allow it in iOS; your body profile is only saved if you choose to enter it. This data is never used for advertising and never sold.
3. Legal bases (EU and UK users)
- Performance of a contract (GDPR Art. 6(1)(b)): account, programs, sessions, history, connections and subscription.
- Explicit consent (GDPR Art. 6(1)(a) and 9(2)(a)): Apple Health data, location during runs and the body profile you enter. You can withdraw it at any time in iOS or app settings.
- Legitimate interests (GDPR Art. 6(1)(f)): service security, technical logs and app usage statistics. [TO VERIFY before the French launch: under CNIL guidance, account-linked statistics require consent]
4. Your assistant (ChatGPT or Claude)
When you connect TWAINING to your assistant, you allow it to view and manage your training data: profile, programs, sessions, notes, steps, sleep if shared, and GPS routes. That data is then sent, at your request, to OpenAI (ChatGPT) or Anthropic (Claude). They handle it under their own terms and privacy policies, as independent controllers.
You can disconnect an assistant from the app. Disconnecting blocks future access; it does not erase what the assistant already received, which remains subject to that service’s policies.
5. Who receives your data
- OVH SAS (France), which hosts our server and database as our processor. Server location: [TO VERIFY: VPS data center, EU expected].
- Apple, for Sign in with Apple, app distribution and subscription payments, under its own terms.
- Stripe, for payments and invoices of subscriptions purchased on twaining.app. [TO REVIEW: Stripe's role, data transfers, retention]
- OpenAI or Anthropic, only if you connect their assistant (see section 4).
We do not sell or rent your data, and we do not “share” it for cross-context behavioral advertising. We may disclose data to authorities when required by law.
6. International transfers
TWAINING is operated from France and your data is stored with our hosting provider in the European Union. If you use TWAINING from the United States, your data is transferred to and processed in the EU. Data you send to your assistant may be processed in the United States by OpenAI or Anthropic.
7. How long we keep data
- Account, training, running, steps and profile data (body and coaching): for as long as your account exists.
- Sleep: while sleep sharing is on. Turning it off erases the nights already sent from our server as soon as the app is online, and your assistant loses access to them. The app keeps reading your sleep on your iPhone for reminders, without sending it.
- Logs of your assistant’s calls: 30 days. Their statistics (tool, result, duration, no content) follow the app usage retention.
- App usage statistics: 25 months.
- Problem reports: until your account is deleted.
- Database backups: about two weeks, then deleted.
When you delete your account in the app (Settings → Delete account), all of its data is removed from our database immediately, its usage statistics within minutes, and everything from backups within 16 days.
8. Security
Traffic is encrypted (HTTPS). Access tokens are stored hashed. Server access is restricted. There is no password to leak: sign-in goes through Apple.
9. The twaining.app website
The website sets no cookies and uses no analytics tools or ad pixels. Our server may keep technical logs (IP address, date, page requested) for security, for [TO VERIFY: server log retention]. If we ever add a measurement tool, we will update this policy before it goes live and ask for your consent where the law requires it.
10. Your rights
Wherever you live, you can ask us to access, correct, delete or export your data, and withdraw your consent. From the app, you can already view and edit your profile, disconnect an assistant, turn off sleep sharing and delete your account. For anything else, email contact@twaining.app. We respond within 30 days. We will not discriminate against you for exercising your rights.
EU and UK users
You also have the right to restrict or object to processing and to lodge a complaint with a supervisory authority, such as the French CNIL (cnil.fr) or the authority where you live.
US users
Depending on your state (for example California, Colorado, Connecticut, Virginia, Washington or Nevada), you may have the right to know what personal data we collect, to access, correct and delete it, to obtain a portable copy, and to opt out of its sale, sharing for targeted advertising or profiling. We do not sell personal data, do not use it for targeted advertising and do not profile you in ways that produce legal or similarly significant effects. You may use an authorized agent; we may need to verify your identity before acting on a request. If we deny a request, you may appeal by replying to our answer.
Consumer health data
Steps, sleep, your body profile, training effort and precise location can be “consumer health data” under laws such as Washington’s My Health My Data Act. We collect it only to provide the features you use, with your consent; we never sell it; we share it only with the processors and services listed above, including the assistant you choose to connect. You can withdraw consent and request deletion as described in this section.
11. Minimum age
TWAINING is for people aged 16 and over. We do not knowingly collect data from children under 13; if you believe a child has created an account, contact us and we will delete it.
12. Changes
If we make a material change, we will let you know in the app or on this page before it takes effect. The version date is shown at the top of this page.