This Policy describes what personal data the FORMA PRIME app and website (the “Service”) process, for what purpose, on what legal basis, and how we protect it. The Policy complies with the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679).
The controller of personal data is Exsov OÜ (registry code 16300767, registered in Estonia), Kaupmehe tn 7-63, Kesklinna linnaosa, 10114 Tallinn, Estonia. For any questions about your data: support@formaprime.app.
Nutrition, weight and body data may qualify as health data. We process it solely to operate the Service, at your initiative, and never for advertising.
| Data | Purpose | Legal basis |
|---|---|---|
| Account, nutrition, workouts, goals | Providing the Service’s features, calorie and target calculations, diary, statistics | Performance of a contract — Art. 6(1)(b); health data — explicit consent, Art. 9(2)(a) |
| Apple Health / Health Connect steps | Optional display of daily activity and in-app rewards; read-only access | Explicit consent — Art. 6(1)(a), 9(2)(a) |
| Photos and AI requests | Recognition at your request and an automated estimate | Consent — Art. 6(1)(a); health data — Art. 9(2)(a) |
| Trainer relationship and permitted data | Connecting a trainer, delivering assignments and messages, and operating non-cash points/PRO gifts | Performance of a contract — Art. 6(1)(b); health data — explicit consent, Art. 9(2)(a) |
| Subscriptions, Store events and points | Managing entitlement, accounting for refunds, preventing abuse and processing PRO gifts | Performance of a contract — Art. 6(1)(b); legal obligation — Art. 6(1)(c); legitimate interest — Art. 6(1)(f) |
| Technical / stability data | Security and improvement of the Service | Legitimate interest — Art. 6(1)(f) |
Trainer access. An actively connected trainer is not an independent marketing recipient. The trainer can access only workout and/or nutrition data for which you gave separate permission. You can revoke a permission or disconnect in the app; new access then stops. Assignments and messages already delivered to you may remain in your account history until you delete them or delete the account.
We do not sell your personal data and do not share it with third parties for their own marketing.
Some processors (e.g. AI providers) may process data outside the European Economic Area, including in the USA. In such cases the transfer relies on European Commission adequacy decisions (e.g. the EU–US Data Privacy Framework) and/or the EU Standard Contractual Clauses (SCC), which ensure an adequate level of protection.
Data is kept while your account is active. You can delete your account and related data at any time in the app: Profile → Delete account, or through the support page. You may also send a request to support@formaprime.app. After deletion, user data is erased or irreversibly anonymised. Limited payment, accounting, anti-fraud and audit records may be kept for as long as required by law or needed to protect legal rights; Apple, Google and RevenueCat separately retain Store records under their own policies.
You have the right to:
To exercise your rights, write to support@formaprime.app. You also have the right to lodge a complaint with a supervisory authority: in Estonia — the Data Protection Inspectorate (Andmekaitse Inspektsioon, aki.ee), or with the authority of your EU country.
The website uses only strictly necessary technical means (e.g. locally storing your chosen language) and does not use advertising or analytics cookies or third-party tracking. Web fonts are served from the FORMA PRIME domain without requests to third-party font services. A cookie consent banner is therefore not required. The app does not use advertising identifiers for cross-app tracking.
The Service is not intended for persons under 16. We do not knowingly collect children’s data.
Data in transit is protected by encryption (HTTPS/TLS). Access to data is restricted and granted only on a need-to-know basis.
We may update this Policy; the current version is always available on this page with its update date.
Exsov OÜ · support@formaprime.app