Privacy Policy for Project Prime

1. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

Dennis Vollmer
Wiehenstraße 28
32289 Rödinghausen
Germany
Email: info@projectprime.de

Wherever this privacy policy refers to "we", "us", "Project Prime" or "the app", this refers to the controller named above.

2. Scope

Project Prime is a coaching and tracking app for nutrition, training, body data, progress tracking, recipe management, supplement planning and optional premium features.

The app is aimed at users who want to document and evaluate their nutrition, training and progress data. Depending on usage, data may also be shown to a coach if a corresponding coach access or coach assignment exists.

This privacy policy applies to:

• the mobile Project Prime app for iOS and Android,
• registration, login and account management,
• the Supabase backend and the app data stored there,
• the coach and admin area, where used,
• food, barcode, photo, recipe and AI features,
• supplement features and daily overviews,
• premium, subscription and in-app purchase features, where offered,
• the public website with legal notice, privacy policy, terms of use and support.

3. Brief overview

Project Prime processes in particular account, profile, body, nutrition, training, activity, recipe, supplement, payment status and technical usage data.

Some of this data may constitute health data within the meaning of Art. 9 GDPR or allow conclusions to be drawn about health, fitness, weight development, nutrition, training behavior and lifestyle.

Photos are only processed if users actively use a corresponding feature, for example for loose food items, dishes, meals, barcodes, packaging or nutrition tables.

With another person as a training partner ("GymBuddy"), only a small, clearly limited set of information is shared, and only after both sides agree - no calories, nutritional values or body data. The app sends notifications exclusively about actions of this training partner, and only if they are allowed in the operating system.

Project Prime prioritizes its own database entries. External queries and AI analyses are only meant to take place when required for the respective feature.

Users can delete their account. In doing so, personal data is deleted unless legal retention obligations or legitimate reasons prevent this. General, non-personal food or recipe data may be retained if it is needed for the app's functionality and no longer contains any direct personal reference.

4. Definitions

Personal data is any information relating to an identified or identifiable natural person.

Health data is personal data relating to physical or mental health that can reveal information about a person's state of health.

Processing includes any handling of personal data, for example collecting, storing, displaying, calculating, evaluating, transmitting, deleting or providing.

Coach means an authorized person who, within the app or a coaching relationship, can gain insight into shared or assigned user information.

5. What data does Project Prime process?

5.1 Account and access data

• email address,
• password in a technically protected form,
• login status and session data,
• times of registration and login,
• technical authentication information,
• role information, for example user, coach or admin, where applicable.

5.2 Profile and coaching data

• name or display name,
• profile picture, if voluntarily provided,
• coaching goal, for example losing weight, losing fat, building muscle, maintaining weight or gaining weight,
• coach assignment, if a coaching context exists,
• premium status or manually granted access, where required.

5.3 Body and goal data

• current weight, starting weight and target weight,
• weight history with date,
• height, age and gender,
• metabolic adjustment in kilocalories, if entered,
• automatically calculated daily targets for calories, protein, carbohydrates, fat, water and steps.

5.4 Nutrition data

• entered food, beverages and meals,
• meal category, for example breakfast, lunch, dinner or snack,
• grams, portions, pieces, bars, slices or other units, where available,
• calories, protein, fat, carbohydrates and other nutritional information,
• manually entered activity calories,
• daily notes in the diary,
• entries taken over from saved recipes or saved dishes.

5.5 Beverages

Beverages may be processed like food if they are relevant for nutrition tracking, for example cola, juice, dairy drinks, smoothies or alcoholic beverages. Name, quantity, calories, macronutrients and, where applicable, barcode or product information may be recorded.

5.6 Training and activity data

• training days and training notes,
• training plans, training units and exercises,
• sets, repetitions, weights and exercise performance,
• cardio training types, duration, intensity and calories burned, if entered,
• training duration via start/stop function,
• subjective information such as difficulty, energy, pump feeling, pain and comments,
• exercise progress and charts per exercise,
• evaluation of minutes and units trained over the last seven days.

5.7 Photo, camera and image data

• photos of loose food items, dishes, meals, packaging and nutrition tables,
• barcode and product images if a product is not found,
• information derived from photos, such as recognized food items, product names, brands, barcode/EAN, nutritional values and portions,
• user notes on photos, for example "the meat is venison" or "name: chili con carne".

Photos are generally only processed for analysis triggered by the user. Users should not upload photos that show uninvolved third parties, private documents, addresses or other unnecessary personal information.

5.8 Recipe, dish and community data

• own saved recipes and dishes,
• name, ingredients, quantities, units, portions and calculated nutritional values,
• preparation instructions, if a recipe is to be made available to the community,
• moderation status, AI review note, approval or rejection status,
• public display of approved recipe ideas within the app.

5.9 Supplement data

• voluntary information on diet and supplement goals,
• answers to questions about the supplement suggestion,
• additional notes voluntarily entered by users,
• selected or manually added supplements,
• daily check-off or intake status, where used.

5.10 Health and activity data from the device

As far as users allow this, Project Prime can read the following data from Health Connect on Android or Apple Health/HealthKit on iOS:

• steps as well as active and total calories burned,
• workouts recorded by a watch or another app (type, start, end and, where available, distance),
• sleep and sleep stages, resting heart rate, heart rate variability (HRV), respiratory rate and blood oxygen,
• weight and body fat percentage.

Access only takes place after explicit authorization within the operating system. Which data is requested depends on whether the user has stated that they use a wearable (for example a smartwatch). Project Prime only reads this data and does not write any data to Health Connect or Apple Health. Users can revoke the authorization at any time in their device settings. Details, in particular which of this data stays on the device only, are given in section 19.

5.11 Premium, subscription and payment status

• selected plan, for example monthly or yearly,
• premium status and term information,
• store information from Apple or Google, where required for activation,
• subscription events such as start of the trial, first payment, renewal, cancellation or end, each with time, product and end of term,
• a voluntary statement of the reason for cancellation with optional free text (see section 25),
• participation in an offer after cancelling during the trial (see section 25),
• information on whether an account was manually activated as premium.

Payment data such as complete credit card information is not processed by Project Prime itself, but through the respective app store providers, as far as in-app purchases or subscriptions are offered.

5.12 Technical data

• device and app information, where technically required,
• app version, build number and platform,
• update status and force-update configuration,
• IP address and connection data when communicating with backend, AI and database services,
• error and usage events that occur during operation of the app or backend services,
• internal, account-related usage statistics, for example from which app area a premium notice was opened and how far a purchase got (selected plan, product, outcome and, where applicable, the error message returned by the app store),
• locally stored app states, settings and session information,
• an anonymous count of the first steps of new installations without any identifier (see section 27),
• on iPhone, an anonymous installation report via Apple's SKAdNetwork without any identifier (see section 27),
• after consent, events for ad measurement with Meta (opening the app, account created, purchases) together with technical device information and the advertising ID (on iPhone only after permission in Apple's tracking prompt, see section 27).

5.13 Level, badge and streak data

Project Prime calculates an internal experience point total (XP) and a level derived from it based on activities already recorded (for example meals, training, weight, steps, water and supplements). Users can select an unlocked badge to be displayed on their profile picture.

Regular app use is likewise used to calculate and display a streak (number of consecutive active days), the status of any streak protection shields, and progress on weekly quests.

This does not involve collecting any additional personal data beyond what is already described elsewhere in this policy. XP total, level, selected badge, streak status and weekly quest progress are stored via the Supabase backend, like the other app data.

5.14 Creator code and voucher data

Users can redeem a partner's creator code once. The code does not itself grant premium access or any free period; it attributes the account to the respective partner and leads to an offer code from the relevant app store, with which a paid subscription can be taken out on discounted terms. The redeemed code and the time of redemption are stored in the process.

Separately, users can redeem a gift voucher code once, which immediately grants a time-limited free premium period. The redeemed code, the time of redemption and the end of the granted period are stored in the process.

If the user takes out a paid subscription after redeeming a creator code, it may be recorded internally that this purchase can be linked to the prior code redemption, together with the product purchased and the time of the purchase. This link is used exclusively to calculate revenue-share payments to the respective partner and to measure the performance of individual codes. Partners do not receive any individual personal data, only aggregated figures, for example the number of redemptions and the resulting purchases per code.

5.15 Training partner, invitation and notification data

• an existing or requested connection to a training partner ("GymBuddy"), with the time of the request and of the agreement,
• for each day, whether a workout or a nutrition entry was logged, and the freely chosen workout name,
• sent reactions, images that can be viewed once ("snapshots") and shared challenges,
• your own invite code, a redeemed invite code with the time of redemption, the time of a later purchase by the invited person, and credited premium days,
• for notifications, the device identifier assigned by the notification service (push token), the platform (Android or iOS) and the language of the notifications.

Details on these features, recipients and retention periods are set out in section 28.

6. Purposes of processing

Processing takes place in particular for the following purposes:

• providing the app and the user account,
• registration, login, session management and account security,
• displaying and calculating nutrition, training, water, step and weight data,
• calculating individual daily targets and meal guidelines,
• documenting progress and statistics,
• food, beverage, barcode, packaging, recipe and dish recognition,
• building and maintaining an in-house food and product database,
• reducing external AI and database queries by reusing confirmed data,
• storing personal recipes and dishes for later reuse,
• moderation and approval of community recipes,
• supplement suggestions and supplement tracking,
• calculating experience points (XP), level, streak and weekly quest progress, and displaying a selected badge,
• administering creator codes to attribute users to partners, and linking later purchases for aggregated revenue-share reporting to partners,
• redeeming gift voucher codes for a time-limited free premium period,
• connecting with a training partner and displaying shared workout days, reactions, snapshots and challenges,
• running the invitation program, including checking whether an invited person has taken out a paid subscription, and crediting premium days,
• notifications about actions of the training partner,
• coach evaluation and support, where a coaching relationship exists,
• providing premium features and managing usage limits,
• internal analysis of which app area a premium notice was opened from, in order to improve features and offers,
• troubleshooting, abuse prevention, security and technical stability,
• fulfilling legal obligations and asserting legal claims.

7. Legal bases

We only process personal data if there is a legal basis for doing so. Depending on the feature, the following legal bases apply in particular:

8. Consent when the app is first launched

When the app is launched for the first time, the user is actively asked to consent to Project Prime processing health, fitness, nutrition, training, photo and progress data in order to provide the app.

Consent must not be pre-selected. The user must be able to open the privacy policy and must actively confirm the processing.

Without this consent, features that process health and fitness data cannot be used, or can only be used to a limited extent.

9. Registration, login and password

A user account is required to use the app. Users register with an email address and a password. The password is not stored in plain text.

During registration, a password may need to be repeated to avoid input errors. To recover a forgotten password, users can use the email features of the authentication provider, where these are enabled.

Alternatively, users can log in with "Continue with Google" or "Continue with Apple". In this case, Google or Apple confirms the user's identity and transmits a technical login token as well as, where released by the user, email address and name to our authentication provider, so that it can create or recognize a user account. No password is stored with us in this case. Apple also allows a private relay email address to be used instead of the real email address.

Login sessions can be stored locally on the device so that users do not have to log in again every time they start the app.

10. Supabase as backend service

Project Prime uses Supabase as a backend service for authentication, database, access protection, role management and storage of app data.

Supabase may in particular process account, profile, nutrition, training, weight, role, premium, recipe, food, supplement, update and review data records.

Supabase may be used as a data processor. According to the current state of the project, the server region is Frankfurt, Germany, or the EU.

Access to data is restricted by technical rules, roles and access rights. Users should generally only be able to see their own personal data. Coach or admin access is to be restricted to authorized accounts.

11. In-house food and product database

Project Prime uses its own food and product database. When a user adds a food item, beverage or product, a data record with name, nutritional values, brand, barcode/EAN, portion information, search terms and source may be stored.

The goal is to answer future search queries faster, more reliably and with fewer external requests. If an entry is reliably found in the in-house database, it can be used without a renewed AI query.

General food items without a brand, for example "apple", "skyr", "iceberg lettuce" or "whole grain bread", may be stored as general baseline values. Branded products captured via barcode or packaging may additionally be stored with barcode and brand.

Such data records generally serve the general functionality of the app and are not intended to be permanently displayed publicly in association with a specific person. They may be retained after deletion of a user account if they no longer contain any personal reference.

If a user corrects the nutritional values of a food item, that correction initially applies to their own account only; the shared data remains unaffected. The food item concerned, the changed values and the time of the change are stored. In addition, the change may be added to an internal review list so that clearly incorrect values in the shared database can be identified and corrected there. Adoption into the shared data only takes place after review by the controller.

12. Manual food search

Users can manually search for food and beverages. The app searches its own database first. If a matching general or saved entry exists, it is shown preferentially.

If no matching in-house entry is found and it is a general food item or beverage without a specific brand, the app may estimate nutritional values or supplement them from external sources. If a specific brand or product is searched for and is not available, the app may point to barcode scanning or a product photo.

Manual search may be limited in the free plan. Search queries may be counted in order to technically implement free and premium features.

13. Barcode scanning and packaged food

For packaged food, users can scan the barcode. The app first checks its own database. If a matching data record is found there, the product can be shown without AI analysis and without an external product search.

If the product is not known, the app may query OpenFoodFacts using the barcode. If plausible nutritional values are found there, they can be displayed and, after confirmation, stored in the in-house database.

If insufficient data is found, the app may ask the user to photograph the front of the package and the nutrition table. Product name, brand, nutritional values and, where applicable, portion information can be extracted from this.

If a portion, piece, bar or comparable unit is recognized, it may be shown as an additional selection option. By default, the value per 100 g should be shown unless something else is selected.

Barcode products that were not found or were entered manually may be stored in a review list so that the information can later be checked or corrected.

14. Loose food items

For loose food items, for example fruit, vegetables, meat, eggs, cheese, bread or salad without a barcode, users can take a photo. The AI can first recognize which food item is shown.

The app then searches its own database first. If a reliable match is found there, the nutritional values from the database are used. An additional AI nutrition estimate is then generally not required.

If no reliable match is found, the app may estimate nutritional values or supplement them from external sources and save the entry after confirmation. If a typical portion can reasonably be determined, for example for an apple, banana, egg, slice of bread or similar food items, a portion unit may additionally be saved.

15. Photographing a dish or meal

Users can photograph dishes or meals, for example plates, bowls, tartare rolls, döner, currywurst or filled bread rolls. Users can additionally enter a note, such as "the meat is venison" or "name: chili con carne".

The app can estimate the dish and show an overall figure for calories and macronutrients. Alternatively, recognized components can be entered individually.

In the background, the app can compare recognized components with its own database. If components are not available, general baseline values may be generated and saved so that future recognitions are cheaper and more consistent.

Users can optionally save an estimated dish for themselves. Saved dishes are generally personal entries of the respective account and are not automatically visible to all users.

Estimated dishes may additionally be saved as a review record so that the plausibility of the estimates can be checked and improved.

16. Capturing, dictating and saving recipes

Users can manually capture recipes or dictate ingredients by voice. Voice input uses the operating system's speech recognition, where available. Users can enter ingredients with quantities, grams, count or comparable units.

Required fields may in particular be the name of the dish and the number of servings. The app calculates the nutritional values of the overall recipe and the desired serving from the ingredients and quantities.

For ingredients, the app searches its own database first. If ingredients are not available, general nutritional values may be estimated and saved as a baseline value. Where appropriate, a typical portion, piece count or slice may additionally be saved.

Users can save their own recipes personally and select them again later. Personal recipes can be deleted again by the user.

Users can voluntarily make a recipe available to the community. In this case, preparation instructions must be provided. The recipe is first reviewed and only becomes visible to other users after approval.

17. Community recipes and moderation

Submitted community recipes may contain name, ingredients, preparation instructions, servings, calories, protein, categories, notes and other nutritional values.

Since community recipes may later be shown to other users, users may not submit personal data, insults, discriminatory content, unlawful content, confidential information belonging to others, or content that is problematic under copyright law.

New recipe ideas are first saved for review. The app may carry out an AI pre-check, in particular for grossly inappropriate, insulting, discriminatory, racist, sexist or otherwise unlawful content. In addition, a manual approval is carried out by the controller or an authorized person.

Community recipes are only intended to become generally visible after approval. Until then, users may be shown a note such as "submitted for review".

If a user account is deleted, approved recipe ideas may generally be retained if they no longer contain any personal reference. If recipe ideas contain personal data, this data is deleted or anonymized upon request.

18. Supplement features

Project Prime may contain a supplement area. Users can manually enter supplements or receive a non-binding suggestion based on voluntary answers.

Questions may be asked about diet, fish consumption, meat consumption, vegetarian or vegan diets, known deficiencies, individual notes and personal goals.

The information serves to create a structured overview or reminder for dietary supplements. It does not replace a medical diagnosis, laboratory test or medical advice.

Users can adjust, remove, manually add and check off suggested supplements daily, where this feature is used.

19. Health Connect and Apple Health

Project Prime can read the data listed in section 5.10 from Health Connect on Android or Apple Health on iOS if users grant permission within the operating system. Permission is requested once after the questionnaire; users who have stated that they use a wearable are additionally asked for workouts, sleep and body metrics at that point. Otherwise this request only appears when the user opens the respective feature.

Steps and calories: When opening relevant areas, for example the diary or statistics, the app may retrieve the current step count and calories burned. These daily values are stored in the account in order to calculate daily goals, calorie balance and statistics. Permanent background synchronization is only possible within the technical capabilities of the respective operating system.

Workouts from the watch: The app may show workouts from today and yesterday that were recorded by a watch or another app as suggestions in the training area. These suggestions are evaluated on the device only. Only when the user explicitly takes over a workout is a training entry stored in the account (type of workout, date, duration, calories burned and, where available, distance), which is then treated like a training entered by the user.

Sleep, recovery and body metrics: Sleep and sleep stages, resting heart rate, heart rate variability, respiratory rate, blood oxygen, weight and body fat percentage are evaluated and displayed on the device only, for example as an overview of the last night and as an estimate of recovery. These values are not transmitted to Project Prime or third parties and are not stored in the account. The recovery estimate is a guide value and not a medical assessment.

Users can switch off reading health data in the app under Settings > "Notifications & access"; the app then no longer reads any health data. Users can revoke the permission itself at any time in the settings of their device or the respective health app. Without permission, steps and workouts can still be entered manually.

20. AI analysis with Google Gemini

Project Prime uses Google Gemini for selected AI features, for example recognition of food items, dishes, meals, packaging, brands and product names, reading nutrition tables, estimating dishes, recipe and ingredient processing, moderation checks, as well as translating or normalizing search terms, where required.

For AI analysis, image data, product names, nutritional information, ingredient lists, user notes and technical context information may be transmitted to Google. Only the data required for the respective analysis is intended to be transmitted.

When improving or comparing dishes, the dishes spoken or typed by the user are transmitted. When comparing, if the app is showing the current day, the day's calorie goal, the calories logged so far, the protein goal and the protein logged so far are also transmitted so that the recommendation fits where the day stands. If the user has stated a diet or food intolerances in the questionnaire, these are transmitted as well so that the suggestions take them into account. No name, email address or other account data is transmitted.

Foods and products that are not yet in the in-house database may be looked up during estimation using the Google Search feature of Google Gemini, in order to determine nutritional values as accurately as possible, for example those of the manufacturer. Only the name of the food or product is transmitted for this.

AI results may be inaccurate or incomplete. Users should review entries and can adjust recognized values in the app, as far as the feature allows for this.

The app is designed to prioritize confirmed in-house database entries in order to avoid unnecessary AI queries.

Logging meals via WhatsApp: Users can voluntarily connect their account to WhatsApp and send meals as text, voice message or photo to the Project Prime bot; without Premium, a limited number of entries is free. For this, the WhatsApp phone number is linked to the account. The messages are received and answered via the WhatsApp Business Platform of Meta Platforms Ireland Ltd. and passed to Google Gemini for analysis. Photos and voice messages are processed only for the analysis and are not stored. The recognized meal with its nutrition values and the link between phone number and account are stored. The bot's reply contains the progress for the day (calories and protein relative to the daily goal). The connection can be removed at any time in the app settings; it is also deleted when the account is deleted. WhatsApp's privacy notice additionally applies to processing by WhatsApp.

21. OpenFoodFacts and USDA

OpenFoodFacts may be used to retrieve product information and nutritional values, in particular for packaged food and barcodes.

USDA may serve as an additional data source for general food items, in particular if in-house or German data is not sufficient. The app is intended to use external data sources sparingly and to prioritize confirmed in-house data.

For external data sources, their own terms of use and privacy information may apply. OpenFoodFacts and USDA generally only receive the search query or the barcode, but no complete user profiles, unless implemented differently for technical reasons.

22. Nutrition, training, weight and statistics

Users can save food, beverages, meals, water, steps, activity calories, training days, notes, supplements and weight entries.

From this, the app creates daily overviews, statistics, progress displays, weight charts, meal targets, calorie trends, training evaluations and supplement status.

This data may be shown to the coach if the user is being supported in a coaching context and a corresponding assignment exists.

Sharing a workout or week: Users can create an image (sticker) for a workout or their weekly review and pass it on to an app of their choice via the device's share function or clipboard, for example into an Instagram story. The image is created on the device and only contains the information visible on it; weight is not included. Project Prime itself does not transmit anything in the process. The terms of the app to which the user passes the image apply to its further use.

23. Coach area and coach access

The coach area allows authorized coach or admin accounts to view data of supervised users. This may include profile, body data, weight history, nutrition days, meals, training data, notes, supplement status and other progress data.

Access is to be restricted to authorized persons. Coach and admin accounts must be specially protected. Access follows the principle that only data required for supervision, evaluation and feedback should be visible.

Connection between coach and client: A coach can invite a user via their email address. The coach only sees this user's name and data once the user explicitly accepts the invitation in the app. We store the connection with its status, the times of the request and the response, and an optional note or message from the coach to the client. The user can end the connection at any time in the app under "My coach"; the coach then no longer has access. Coach access can be granted for a limited trial period and then ends automatically.

If a coach export or comparable feature is temporarily not visible, the underlying technical tables or previous data may nevertheless continue to exist, as far as they are required for administration, evidence or later activation.

24. Premium, free plan and usage limits

Project Prime may offer a free use with a limited feature scope and a premium use. To that end the app counts the use of individual features, for example photo analyses, voice capture, barcode scans, recipe features or training plan features. Counting takes place server-side per account and per feature, either once or per calendar month depending on the feature. Manual food search is not limited.

If a limit is reached, a notice about premium may be shown. Users can voluntarily purchase premium, as far as this feature is enabled in the App Store or on Google Play.

Individual accounts can be manually activated by the controller, for example for testing, coaching, support or goodwill purposes. In doing so, only the technical premium status required for activation is processed.

25. App Store, Google Play and payment processing

If the app is downloaded via the Apple App Store or Google Play, or a subscription is concluded there, Apple or Google process personal data under their own responsibility.

Project Prime generally only receives the information required to recognize and activate the premium status. Complete payment information such as credit card data is not stored by Project Prime.

Cancellation, plan changes, renewal and management of subscriptions generally take place via the respective app store, i.e. the Apple App Store or Google Play, as far as the subscription was concluded there.

Question about the reason for cancellation: If a user has cancelled their subscription, the app may ask once what was missing. Answering is voluntary. We store the selected reason, optional free text, the product concerned, whether the cancellation happened during the trial, the end of the term and the app language. We use this information to improve the app. The legal basis is Art. 6(1)(f) GDPR.

Offer after cancelling during the trial: Users who cancel during the free trial may see a discounted offer for the yearly subscription in the app shortly before the trial ends, and may receive one notification about one day before the trial ends. To measure whether the offer helps, it is randomly determined whether a user receives the offer or not. We store this group, the product, the end of the term and the times at which the offer was shown, a purchase was started or the offer was accepted, and a notification was sent. On iPhone, our server creates the signature required by Apple for the offer; no health data is transmitted in this process. The purchase itself is handled by Apple or Google. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is making a suitable offer and measuring its effect.

Public App Store reviews: We store the reviews of our app that are publicly visible in the App Store (displayed name of the author, stars, title, text, app version and date) in order to evaluate feedback. The legal basis is Art. 6(1)(f) GDPR.

26. Update check and forced update

The app may check at launch whether a new minimum version is required. For this, platform, app version and build number may be compared with a configuration in the backend.

If a version is no longer supported for security, functional or compatibility reasons, the app may restrict access until the update is completed. This check serves the security, error prevention and functionality of the app.

27. Local storage on the device

The app may store certain data locally on the device, for example login status, app settings, last selected values, caches and display states.

This local storage serves the usability, performance and offline availability of individual app features.

When the app is deleted, locally stored data may be removed. Data stored on the server is not automatically deleted as a result. Deleting the account within the app or a request to the controller is required for this.

Counting the first steps of new installations: To identify where users leave the app between download and registration, the app reports the following steps at most once per installation: first opening, starting the analysis or choosing "I already have an account", reaching the individual questions of the questionnaire (not the answers), completing the questionnaire, and a newly created account. Only the step, the platform (iOS or Android) and the app's build number are transmitted; the server adds the time. For installations via Google Play, the name of the advertising or referral link through which the app was installed (for example "instagram") is additionally transmitted on first opening and when the account is created, as Google Play passes it to the app on first launch (Install Referrer). This name stands for the link or ad, not for a person. No device or advertising identifier, account ID, name or email address is transmitted, and the IP address is not stored for this count. The entries cannot be attributed to any person and are only evaluated as totals. So that a step is not counted more than once, the app stores a local note that it has already been reported. After a reinstallation, counting starts again. The entries are stored with Supabase and deleted after 12 months at the latest.

Ad measurement with Meta (only with consent): So that we can show our ads on Facebook and Instagram more specifically to people who are interested in the app, the app asks new users once, within the first 7 days after registration, whether they agree to ad measurement. The decision can be changed at any time under Settings > Data & privacy > Ad measurement. Without consent, measurement stays switched off. Only after consent does the software development kit (SDK) of Meta Platforms Ireland Ltd., Merrion Road, Dublin 4, Ireland, built into the app transmit the following events to Meta: opening the app (from which Meta recognizes the installation), once the creation of the account with the login method, and purchases and subscriptions in the App Store or on Google Play (product, price, currency). Meta processes technical information such as device model, operating system, app version, language setting and IP address and, on Android devices, the advertising ID (Google Advertising ID). On iPhones, consent is requested via Apple's tracking prompt (in older app versions following the app's own question). The iPhone's advertising ID (IDFA) is only transmitted if users choose "Allow" there. Health, nutrition, training and body data, name and email address are never transmitted to Meta. Meta uses the information to attribute installations and purchases to our ads, to improve ad delivery and to provide us with aggregated reports. Where Meta also processes the data for its own purposes, Meta is responsible for this itself; see Meta's privacy policy (https://www.facebook.com/privacy/policy). After consent is withdrawn, the app no longer transmits any events to Meta. The legal basis is Art. 6(1)(a) GDPR in conjunction with Section 25(1) TDDDG.

Anonymous install count via Apple (iPhone only): On first launch, the app reports once via Apple's SKAdNetwork interface that it has been opened. If the user tapped one of our ads before installing, Apple then sends a delayed confirmation to the ad network (Meta), which shows us the number of installations per campaign. Apple creates and sends this confirmation itself. It contains no device or advertising identifier (IDFA), no name, no email address and no health, nutrition, training or body data, and Apple only passes it on in a way that cannot be attributed to any person or device. The app itself does not transmit anything to Meta in this process. This count takes place independently of ad measurement with Meta and of Apple's tracking prompt. To the extent that personal data is processed at all, the legal basis is Art. 6(1)(f) GDPR; our legitimate interest is measuring the success of our advertising. More information from Apple: https://developer.apple.com/documentation/storekit/skadnetwork

28. Training partner ("GymBuddy"), invitations and notifications

The app allows you to connect with exactly one other person as a training partner. This connection is always mutual: one person enters the other's personal code, and the other must explicitly agree. Without that agreement, only the first name is exchanged: while a request is pending, each side sees only the other person's first name, so it is clear who sent the request or to whom it went. All other information is only exchanged after the agreement.

While a connection exists, the training partner is shown:

• the first name from the profile (not the full name, not the email address),
• for the last 14 days, whether a workout was logged and whether a nutrition entry was made on each day,
• the freely chosen name of a workout (for example "Push" or "Legs"),
• one of two fixed reactions (🔥, 💪), if sent,
• an optionally sent image ("snapshot") that can be viewed exactly once,
• counts derived from those same daily entries for shared goals and duels ("challenges"), for example the number of workouts in the current month or the length of a streak. Challenges only run if both sides explicitly agree, and either side can end them at any time.

Explicitly NOT transmitted: calorie or nutritional values, amounts, weight, body measurements, goals, progress photos, individual foods or meals, and any health data from Health Connect or Apple Health.

The legal basis is Art. 6(1)(b) GDPR (performing a function requested by the user) and, where this constitutes separate consent, Art. 6(1)(a) GDPR.

Retention: at most the daily entries of the last 40 days are stored; older days are deleted whenever the app updates them. Of those, only the last 14 days are shown to the training partner, while the rest are used solely as counts within challenges. A sent image is deleted as soon as it has been viewed. An image that has not been viewed is no longer shown after 48 hours and is deleted no later than four days after sending. Reactions are deleted once displayed; a reaction that has not been displayed is no longer shown after seven days and is deleted the next time the training partner area is opened. Regardless of this, all shared information is deleted when the connection is ended and when the account is deleted.

The connection can be ended at any time, unilaterally and without giving reasons. On disconnecting, all data shared between the two accounts - daily entries, reactions and images not yet viewed - is deleted immediately on both sides.

Note on screenshots: an image shown once can technically be captured by the recipient via a screenshot. This cannot be reliably prevented by the operating system. Users are informed of this in the app before sending.

Invitations: users can share a personal invite code. Another person can enter this code once, during registration or later in the account settings, as long as they have not yet taken out a subscription. The redeemed code and the time of redemption are stored.

If the invited person later takes out a paid subscription, it is checked whether it continues beyond a free trial. For this, their subscription status is evaluated and the time of purchase is linked to the invitation. If the condition is met, premium days are credited to the inviting person. The inviting person is not shown any name, email address or other information about the invited person. From a credit, however, they can infer that a person they invited has taken out a subscription.

Notifications: the app sends notifications exclusively about actions of the training partner, namely a new or accepted connection request, a sent snapshot, a reaction, a proposed or started challenge, and a completed training session. No reminders, advertising or other notices are sent.

The app only asks for permission to send notifications once a connection request has been sent or a connection exists, and at most once per installation. On Android devices up to version 12, notifications are allowed by the operating system without asking. The permission can be withdrawn at any time in the device settings.

Notifications are sent via Google's Firebase Cloud Messaging; on iOS devices, delivery additionally takes place via the Apple Push Notification service. For this, a device identifier assigned by the notification service (push token), the platform and the language of the notifications are stored for each device. A notification contains a fixed text describing the type of action and, for a reaction, the character sent. It does not contain names, images, training or nutrition information.

The device identifier is deleted when the user logs out in the app, when the account is deleted, and when the notification service reports it as invalid, for example after the app has been uninstalled.

29. App permissions

30. Recipients and service providers

Personal data may be transmitted to the following recipients or categories of recipients, as far as this is required for the app, coaching, security or legal obligations:

• Supabase as backend and authentication service,
• Google Gemini for AI analysis,
• Meta Platforms Ireland Ltd. (WhatsApp Business Platform), as far as users connect the WhatsApp bot,
• Meta Platforms Ireland Ltd. (Meta SDK for ad measurement), only if users have consented to ad measurement,
• Google Firebase Cloud Messaging and the Apple Push Notification service for delivering notifications,
• the connected training partner, for the information listed in section 28,
• OpenFoodFacts and USDA for food and product data,
• Apple App Store and Google Play for app distribution and subscriptions,
• Google and Apple as providers of the "Continue with Google" and "Continue with Apple" login options, as far as users choose this login method,
• coach and admin accounts, as far as authorization exists,
• hosting and IT service providers for the website, support and operation,
• legal advisors, tax advisors or authorities, as far as legally required.

31. Transfers to third countries

When using services from international providers, processing may take place outside the European Union or the European Economic Area. This applies in particular to Google (AI analysis, notifications, login with Google), Apple and Meta (WhatsApp bot, ad measurement), which may also process data in the USA.

In such cases, we ensure that appropriate safeguards within the meaning of the GDPR are in place, for example EU standard contractual clauses, adequacy decisions or additional protective measures.

32. Storage period

We only store personal data for as long as is necessary for the respective purposes or as long as legal obligations exist.

Account, profile, nutrition, training, weight, supplement and progress data is generally stored until account deletion or termination of use.

For training partner data, invitations and device identifiers for notifications, the periods set out in section 28 apply.

General, approved food, product and recipe data without a direct personal reference may continue to exist for longer so that the app database remains functional.

Review records, technical logs and security data are deleted or anonymized as soon as they are no longer required for error analysis, quality assurance, security or legal evidence.

33. Account deletion and deletion of personal data

Users can delete their account within the app, as far as this feature is provided. Alternatively, a deletion request can be sent to the contact address named above.

When an account is deleted, the user's personal data is deleted unless legal retention obligations, security reasons or legitimate interests prevent this.

In particular, the following is deleted:

• user account and authentication reference,
• app profile and body data,
• weight history, daily data and notes,
• nutrition and training days,
• personal saved recipes and saved dishes, as far as they are personal,
• supplement plan and daily supplement entries,
• connections to training partners and shared daily entries, reactions, snapshots and challenges,
• your own invite code, redeemed invitations and credited premium days,
• device identifiers for notifications,
• role and access data, as far as it only relates to this account,
• personal review records, as far as technically attributable.

General, non-personal data required for the functionality of the app database does not have to be automatically deleted, for example confirmed general food items, barcode/product data without a personal reference, or approved community recipes without a personal reference.

If such content contains personal data, users can request its deletion or anonymization.

After an account is deleted, we keep a limited record without name or email address to document billing, trial periods and creator commissions and to prevent abuse: the internal account ID, the times of registration and deletion, the last premium status (source, term, trial period), redeemed creator and voucher codes, the history of subscription events, and purchases and purchase attempts (product, platform, time, without the purchase receipt). The legal basis is Art. 6(1)(c) and (f) GDPR. The record is deleted as soon as it is no longer needed for these purposes, at the latest when the statutory retention periods expire.

34. Rights of data subjects

Under the GDPR, users have in particular the following rights:

• right of access under Art. 15 GDPR,
• right to rectification under Art. 16 GDPR,
• right to erasure under Art. 17 GDPR,
• right to restriction of processing under Art. 18 GDPR,
• right to data portability under Art. 20 GDPR,
• right to object under Art. 21 GDPR,
• right to withdraw consent granted under Art. 7(3) GDPR,
• right to lodge a complaint with a data protection supervisory authority.

Requests can be sent to info@projectprime.de.

35. Withdrawal of consent

As far as processing is based on consent, users can withdraw this consent at any time with effect for the future.

Withdrawal may result in certain app features no longer being usable, in particular features for health, nutrition, training, health-app, photo and AI analysis.

36. Automated decisions and profiling

Project Prime creates evaluations, daily targets, meal guidelines, progress displays, AI estimates, training histories, supplement suggestions and recommendations.

These serve to support the user and the coaching. There is no exclusively automated decision with legal effect or similarly significant impact within the meaning of Art. 22 GDPR.

AI results and app evaluations may be inaccurate. They do not replace a medical diagnosis, therapy, medical advice or individual nutritional counseling by an appropriately qualified body.

37. Data security

We take appropriate technical and organizational measures to protect personal data against loss, misuse, unauthorized access, alteration or disclosure.

These include in particular:

• HTTPS connections,
• authentication via user accounts,
• role-based access rights,
• backend security rules,
• separation of user, coach and admin access,
• limiting AI and third-party queries to required data,
• regular review and adjustment of the technical implementation.

38. Minors

The app is generally not aimed at children. Should the app be used by minors, it should first be checked whether consent from a parent or legal guardian is required.

39. Google Play Data Safety and Apple Privacy Labels

For publication of the app in the Google Play Store and the Apple App Store, privacy information is provided in accordance with the actual data processing.

Based on the current feature scope, Project Prime in particular processes the following categories of data:

• account data, for example email address,
• health and fitness data, for example weight, body data, nutrition, training and progress,
• app activity and usage status,
• photos and camera data for analysis triggered by the user, and as a snapshot sent to a connected training partner,
• user content, for example recipes, dishes, notes and community submissions,
• technical identifiers, as far as required for operating the app, for example the device identifier for notifications,
• purchase or subscription status, as far as premium features are used.

The information in the privacy details of the respective app stores is updated accordingly when the feature scope changes.

40. Website, support and contact

The public Project Prime website provides information on the app, support, privacy, terms of use and legal notice.

If users contact us by email, the information provided is processed in order to answer the inquiry. This may include email address, name, content of the inquiry and accompanying technical information.

41. Changes to this privacy policy

We may adapt this privacy policy if features, providers, the legal situation or technical processes change.

The current version is made available in the app or via a suitable link. In the event of material changes, a notice may be given in the app.

42. Contact for privacy questions

For questions about data protection, exercising rights or account deletion, users can contact the controller at the following address:

info@projectprime.de

Appendix A: Overview of key processing activities