# Privacy Policy

Your privacy is important to us. It is Jan Jiráň operating as Routinely's policy
to respect your privacy and comply with any applicable law and regulation
regarding any personal information we may collect about you, including via our
app, Routinely, and its associated services.

Personal information is any information about you which can be used to identify
you. This includes information about you as a person (such as name, address, and
date of birth), your devices, payment details, and even information about how
you use an app or online service.

In the event our app contains links to third-party sites and services, please be
aware that those sites and services have their own privacy policies. After
following a link to any third-party content, you should read their posted
privacy policy information about how they collect and use personal information.
This Privacy Policy does not apply to any of your activities after you leave our
app.

This policy is effective as of February 13, 2026

Last updated: March 1, 2026

## Information We Collect

Information we collect falls into one of two categories: "voluntarily provided"
information and "automatically collected" information.

"Voluntarily provided" information refers to any information you knowingly and
actively provide us when using our app and its associated services.

"Automatically collected" information refers to any information automatically
sent by your device in the course of accessing our app and its associated
services.

### Log Data

When you access our servers via our app, we may automatically log the standard
data provided by your device. It may include your device's Internet Protocol
(IP) address, your device type and version, your activity within the app, time
and date, and other details about your usage.

Additionally, when you encounter certain errors while using the app, we
automatically collect data about the error and the circumstances surrounding its
occurrence. This data may include technical details about your device, what you
were trying to do when the error happened, and other technical information
relating to the problem. You may or may not receive notice of such errors, even
in the moment they occur, that they have occurred, or what the nature of the
error is.

Please be aware that while this information may not be personally identifying by
itself, it may be possible to combine it with other data to personally identify
individual persons.

### Device Data

Our app may access and collect data via your device's in-built tools, such as:

- Your Identity
- Camera
- Microphone
- Storage, photos and/or media
- Notifications
- Background data refresh
- Mobile data
- Device/app history

When you install the app or use your device’s tools within the app, we request
permission to access this information. The specific data we collect can depend
on the individual settings of your device and the permissions you grant when you
install and use the app.

### Personal Information

We may ask for personal information - for example, when you submit content to
us, when you subscribe to our newsletter, when you register an account or when
you contact us — which may include one or more of the following:

- Name
- Email

### User-Generated Content

We consider “user-generated content” to be materials (text, image and/or video
content) voluntarily supplied to us by our users for the purpose of publication
on our platform, app or re-publishing on our social media channels. All
user-generated content is associated with the account or email address used to
submit the materials.

Please be aware that any content you submit for the purpose of publication will
be public after posting (and subsequent review or vetting process). Once
published, it may be accessible to third parties not covered under this privacy
policy.

### AI-Powered Features and Third-Party Data Processing

Our app offers AI-powered features that generate workout routines from video
content or text descriptions you provide. When you use these features, your data
is processed by **Google Gemini AI**, a third-party artificial intelligence
service operated by Google LLC.

**What data is sent to Google Gemini:**

- Video content or URLs you provide for workout generation
- Text descriptions you enter to generate workouts

**What data is NOT sent to Google Gemini:**

- Your name, email, or account information
- Your workout history or session data
- Your device information or usage analytics

Your data is sent to Google Gemini solely for the purpose of generating workout
content and is processed in accordance with Google's privacy policies. Video
files uploaded for processing are temporarily stored on Google's servers for up
to 48 hours and are then automatically deleted. Text descriptions are processed
in real time and are not persistently stored.

**You will be asked for explicit consent** before any data is sent to Google
Gemini for AI processing. You may decline and continue using the app without
AI-powered features. Your consent preference is stored in your account and can
be revoked by contacting us.

## Legitimate Reasons for Processing Your Personal Information

We only collect and use your personal information when we have a legitimate
reason for doing so. In which instance, we only collect personal information
that is reasonably necessary to provide our services to you.

## Collection and Use of Information

We may collect personal information from you when you do any of the following on
our app:

- Register for an account
- Sign up to receive updates from us via email or social media channels
- Post a comment or review or otherwise participate in our online community
- Use a mobile device or web browser to access our content
- Contact us via email, social media, or on any similar technologies
- When you mention us on social media

We may collect, hold, use, and disclose information for the following purposes,
and personal information will not be further processed in a manner that is
incompatible with these purposes:

- to provide you with our app's core features and services
- to enable you to customize or personalize your experience of our app
- to process your video or text content using AI services (Google Gemini) for
  workout generation, with your explicit consent
- to contact and communicate with you
- for analytics, market research, and business development, including to operate
  and improve our app, associated applications, and associated social media
  platforms
- for technical assessment, including to operate and improve our app, associated
  applications, and associated social media platforms

We may combine voluntarily provided and automatically collected personal
information with general information or research data we receive from other
trusted sources. For example, If you consent to us accessing your social media
profiles, we may combine information sourced from those profiles with
information received from you directly to provide you with an enhanced
experience of our app and services.

## Security of Your Personal Information

When we collect and process personal information, and while we retain this
information, we will protect it within commercially acceptable means to prevent
loss and theft, as well as unauthorized access, disclosure, copying, use or
modification.

Although we will do our best to protect the personal information you provide to
us, we advise that no method of electronic transmission or storage is 100%
secure and no one can guarantee absolute data security.

You are responsible for selecting any password and its overall security
strength, ensuring the security of your own information within the bounds of our
services. For example, ensuring any passwords associated with accessing your
personal information and accounts are secure and confidential.

## How Long We Keep Your Personal Information

We keep your personal information only for as long as we need to. This time
period may depend on what we are using your information for, in accordance with
this privacy policy. For example, if you have provided us with personal
information as part of creating an account with us, we may retain this
information for the duration your account exists on our system. If your personal
information is no longer required for this purpose, we will delete it or make it
anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information for our
compliance with a legal, accounting, or reporting obligation or for archiving
purposes in the public interest, scientific, or historical research purposes or
statistical purposes.

## Children’s Privacy

We do not aim any of our products or services directly at children under the age
of 13 and we do not knowingly collect personal information about children
under 13.

## Disclosure of Personal Information to Third Parties

We may disclose personal information to:

- a parent, subsidiary or affiliate of our company
- third-party service providers for the purpose of enabling them to provide
  their services, including (without limitation) IT service providers, data
  storage, hosting and server providers, analytics, error loggers, debt
  collectors, maintenance or problem-solving providers, professional advisors,
  and payment systems operators
- our employees, contractors, and/or related entities
- our existing or potential agents or business partners
- credit reporting agencies, courts, tribunals, and regulatory authorities, in
  the event you fail to pay for goods or services we have provided to you
- courts, tribunals, regulatory authorities, and law enforcement officers, as
  required by law, in connection with any actual or prospective legal
  proceedings, or in order to establish, exercise, or defend our legal rights
- third parties, including agents or sub-contractors who assist us in providing
  information, products, services, or direct marketing to you
- third parties to collect and process data
- an entity that buys, or to which we transfer all or substantially all of our
  assets and business

Third parties we currently use include:

- **Google Gemini** (Google LLC) — AI-powered workout generation from video and
  text content, with your explicit consent
- **Clerk** (Clerk, Inc.) — User authentication and account management
- **Convex** (Convex, Inc.) — Backend data storage and serverless functions
- **Statsig** (Statsig, Inc.) — Analytics and feature management
- **RevenueCat** (RevenueCat, Inc.) — Subscription and payment management
- **Apple Pay** — Payment processing

## Your Rights and Controlling Your Personal Information

**Your choice:** By providing personal information to us, you understand we will
collect, hold, use, and disclose your personal information in accordance with
this privacy policy. You do not have to provide personal information to us,
however, if you do not, it may affect your use of our app or the products and/or
services offered on or through it.

**Information from third parties:** If we receive personal information about you
from a third party, we will protect it as set out in this privacy policy. If you
are a third party providing personal information about somebody else, you
represent and warrant that you have such person’s consent to provide the
personal information to us.

**Marketing permission:** If you have previously agreed to us using your
personal information for direct marketing purposes, you may change your mind at
any time by contacting us using the details below.

**Access:** You may request details of the personal information that we hold
about you.

**Correction:** If you believe that any information we hold about you is
inaccurate, out of date, incomplete, irrelevant, or misleading, please contact
us using the details provided in this privacy policy. We will take reasonable
steps to correct any information found to be inaccurate, incomplete, misleading,
or out of date.

**Non-discrimination:** We will not discriminate against you for exercising any
of your rights over your personal information. Unless your personal information
is required to provide you with a particular service or offer (for example
serving particular content to your device), we will not deny you goods or
services and/or charge you different prices or rates for goods or services,
including through granting discounts or other benefits, or imposing penalties,
or provide you with a different level or quality of goods or services.

**Notification of data breaches:** We will comply with laws applicable to us in
respect of any data breach.

**Complaints:** If you believe that we have breached a relevant data protection
law and wish to make a complaint, please contact us using the details below and
provide us with full details of the alleged breach. We will promptly investigate
your complaint and respond to you, in writing, setting out the outcome of our
investigation and the steps we will take to deal with your complaint. You also
have the right to contact a regulatory body or data protection authority in
relation to your complaint.

**Unsubscribe:** To unsubscribe from our email database or opt-out of
communications (including marketing communications), please contact us using the
details provided in this privacy policy, or opt-out using the opt-out facilities
provided in the communication. We may need to request specific information from
you to help us confirm your identity.

## Business Transfers

If we or our assets are acquired, or in the unlikely event that we go out of
business or enter bankruptcy, we would include data, including your personal
information, among the assets transferred to any parties who acquire us. You
acknowledge that such transfers may occur, and that any parties who acquire us
may, to the extent permitted by applicable law, continue to use your personal
information according to this policy, which they will be required to assume as
it is the basis for any ownership or use rights we have over such information.

## Limits of Our Policy

Our app may link to external sites that are not operated by us. Please be aware
that we have no control over the content and policies of those sites, and cannot
accept responsibility or liability for their respective privacy practices.

## Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our
business processes, current acceptable practices, or legislative or regulatory
changes. If we decide to change this privacy policy, we will post the changes
here at the same link by which you are accessing this privacy policy.

If the changes are significant, or if required by applicable law, we will
contact you (based on your selected preferences for communications from us) and
all our registered users with the new details and links to the updated or
changed policy.

If required by law, we will get your permission or give you the opportunity to
opt in to or opt out of, as applicable, any new uses of your personal
information.

## Additional Disclosures for General Data Protection Regulation (GDPR) Compliance (EU)

### Data Controller / Data Processor

The GDPR distinguishes between organizations that process personal information
for their own purposes (known as "data controllers") and organizations that
process personal information on behalf of other organizations (known as "data
processors"). We, Jan Jiráň operating as Routinely, located at the address
provided in our Contact Us section, are a Data Controller and/or Processor with
respect to the personal information you provide to us.

### Legal Bases for Processing Your Personal Information

We will only collect and use your personal information when we have a legal
right to do so. In which case, we will collect and use your personal information
lawfully, fairly, and in a transparent manner. If we seek your consent to
process your personal information, and you are under 16 years of age, we will
seek your parent or legal guardian’s consent to process your personal
information for that specific purpose.

Our lawful bases depend on the services you use and how you use them. This means
we only collect and use your information on the following grounds:

#### Consent From You

Where you give us consent to collect and use your personal information for a
specific purpose. You may withdraw your consent at any time using the facilities
we provide; however this will not affect any use of your information that has
already taken place. You may consent to providing your email address for the
purpose of receiving marketing emails from us. While you may unsubscribe at any
time, we cannot recall any email we have already sent. If you have any further
enquiries about how to withdraw your consent, please feel free to enquire using
the details provided in the Contact Us section of this privacy policy.

#### Performance of a Contract or Transaction

Where you have entered into a contract or transaction with us, or in order to
take preparatory steps prior to our entering into a contract or transaction with
you. For example, if you contact us with an enquiry, we may require personal
information such as your name and contact details in order to respond.

#### Our Legitimate Interests

Where we assess it is necessary for our legitimate interests, such as for us to
provide, operate, improve and communicate our services. If you submit comments
intended for publishing on our site, we may require some details about you in
order to identify you as the content author. We consider our legitimate
interests to include research and development, understanding our audience,
marketing and promoting our services, measures taken to operate our services
efficiently, marketing analysis, and measures taken to protect our legal rights
and interests.

#### Compliance With the Law

In some cases, we may have a legal obligation to use or keep your personal
information. Such cases may include (but are not limited to) court orders,
criminal investigations, government requests, and regulatory obligations. If you
have any further enquiries about how we retain personal information in order to
comply with the law, please feel free to enquire using the details provided in
the Contact Us section of this privacy policy.

### International Transfers Outside of the European Economic Area (EEA)

We will ensure that any transfer of personal information from countries in the
European Economic Area (EEA) to countries outside the EEA will be protected by
appropriate safeguards, for example by using standard data protection clauses
approved by the European Commission, or the use of binding corporate rules or
other legally accepted means.

### Your Rights and Controlling Your Personal Information

**Restrict:** You have the right to request that we restrict the processing of
your personal information if:

1. you are concerned about the accuracy of your personal information;
2. you believe your personal information has been unlawfully processed;
3. you need us to maintain the personal information solely for the purpose of a
   legal claim; or
4. we are in the process of considering your objection in relation to processing
   on the basis of legitimate interests.

**Objecting to processing:** You have the right to object to processing of your
personal information that is based on our legitimate interests or public
interest. If this is done, we must provide compelling legitimate grounds for the
processing which overrides your interests, rights, and freedoms, in order to
proceed with the processing of your personal information.

**Data portability:** You may have the right to request a copy of the personal
information we hold about you. Where possible, we will provide this information
in CSV format or other easily readable machine format. You may also have the
right to request that we transfer this personal information to a third party.

## Contact Us

For any questions or concerns regarding your privacy, you may contact us using
the following details:

Support team\
support@approutinely.com