Privacy Policy

1. Introduction

Welcome to FitLog, a product of Top NoCoders FZCO ("we," "our," or "us"), a company registered in the United Arab Emirates (Company Number: 23139). We are committed to protecting your privacy and ensuring the security of your personal information in accordance with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and other applicable data protection laws. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-powered fitness tracking application integrated with ChatGPT.

2. Information We Collect

We collect the following types of information:

• Health and Fitness Data: Food entries, nutritional information (calories, protein, carbs, fats), workout details (duration, distance, calories burned), weight measurements, daily metrics (water intake, steps, sleep hours).
• Goals and Preferences: Your fitness goals, target weight, calorie targets, and other customizable settings.
• Usage Data: Information about how you interact with FitLog through ChatGPT, including timestamps and feature usage patterns.
• Account Information: Information necessary to link your FitLog data with your ChatGPT session.

3. How We Use Your Information

We use your information to:

• Provide and maintain the FitLog service
• Track and display your fitness progress, including daily summaries, weekly analytics, and goal progress
• Calculate nutritional information and calorie budgets
• Generate personalized insights and visualizations
• Improve and optimize our services
• Communicate with you about service updates

4. Legal Basis for Processing (UAE PDPL)

In accordance with the UAE Personal Data Protection Law (PDPL), we process your personal data based on the following legal grounds:

• Consent: You provide explicit consent when you create an account and use FitLog. Health and fitness data is considered sensitive personal data under UAE law, and we obtain your clear consent before processing such data.
• Contractual Necessity: Processing is necessary to provide you with the FitLog service as per our terms of use.
• Legitimate Interest: To improve our services and ensure security, where such interests do not override your fundamental rights.
• Legal Obligation: Where we are required to process data to comply with UAE law.

You may withdraw your consent at any time by contacting us or deleting your account. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

5. Sensitive Personal Data

Health and fitness information, including your weight, food intake, workout data, and body measurements, is considered sensitive personal data under the UAE PDPL. We process this sensitive data only with your explicit consent and implement enhanced security measures to protect it. You may withdraw consent for processing sensitive data at any time, though this may affect our ability to provide certain services.

6. Data Storage and Security

Your data is stored securely using industry-standard encryption and security measures. We use Supabase for data storage, which provides enterprise-grade security including encryption at rest and in transit. We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.

7. Data Sharing and Disclosure

We do not sell your personal information. We may share your information only in the following circumstances:

• Service Providers: With trusted third-party service providers who assist us in operating our service (e.g., cloud hosting providers)
• Legal Requirements: When required by law or to respond to legal process
• Protection of Rights: To protect our rights, privacy, safety, or property, and that of our users

8. Your Rights Under UAE PDPL

Under the UAE Personal Data Protection Law (PDPL), you have the following rights regarding your personal data:

• Right of Access: Request a copy of your personal data and information about how it is processed.
• Right to Rectification: Request correction of inaccurate or incomplete personal data.
• Right to Erasure: Request deletion of your personal data when it is no longer necessary for the purpose it was collected.
• Right to Data Portability: Receive your personal data in a structured, commonly used, machine-readable format.
• Right to Restrict Processing: Request limitation of processing in certain circumstances.
• Right to Object: Object to processing of your personal data for specific purposes.
• Right to Withdraw Consent: Withdraw your consent at any time where processing is based on consent.
• Right Against Automated Decision-Making: Not be subject to decisions based solely on automated processing, including profiling, that significantly affects you.
• Right to Lodge a Complaint: File a complaint with the UAE Data Office if you believe your data protection rights have been violated.

To exercise any of these rights, please contact us at contact@azkytech.com. We will respond to your request within 14 days as required by UAE law.

9. Cross-Border Data Transfers

In accordance with UAE PDPL requirements, we may transfer your personal data outside the UAE only when:

• The receiving country provides an adequate level of data protection as recognized by UAE authorities;
• Appropriate safeguards are in place, such as standard contractual clauses or binding corporate rules;
• You have provided explicit consent for the transfer after being informed of potential risks; or
• The transfer is necessary for the performance of our contract with you.

Our service providers, including cloud hosting (Supabase) and AI services (OpenAI), may process data in locations outside the UAE. We ensure that appropriate data protection agreements are in place with all such providers to safeguard your personal information.

10. Third-Party Services

FitLog operates as a ChatGPT widget and integrates with OpenAI's services. Your use of ChatGPT is subject to OpenAI's privacy policy and terms of service. We recommend reviewing OpenAI's privacy practices to understand how your conversation data may be processed.

11. Data Retention

In accordance with UAE PDPL data minimization principles, we retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Specifically:

• Active account data is retained while your account remains active.
• Upon account deletion request, we will remove your personal data within 30 days.
• Some data may be retained longer if required by UAE law or for legitimate business purposes (e.g., financial records).
• Anonymized or aggregated data that cannot identify you may be retained indefinitely for analytics purposes.

12. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the UAE Data Office immediately as required by the PDPL. If the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay, providing information about the nature of the breach, potential consequences, and measures taken to address it.

13. Children's Privacy

FitLog is not intended for use by individuals under the age of 18 in the UAE, or under the age of 13 in other jurisdictions. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without appropriate parental consent, we will take steps to delete such information promptly.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date. Where required by UAE PDPL, we will obtain your consent for any changes that materially affect how your personal data is processed. You are advised to review this Privacy Policy periodically for any changes.

15. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at: