Privacy Policy

This Privacy Policy covers the e-commerce website turg.fitness.ee (the "Website") and the Fitness.ee mobile app (the "App"; together, the "Services"). Two Estonian companies are responsible for them: OÜ Robocop runs the Website and is the seller of all Market orders, and Fit Labs OÜ runs the App (see section 2). "We", "us" and "our" mean the company responsible for the processing in question. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data in accordance with the European Union General Data Protection Regulation (GDPR) and Estonian data protection laws.

We are committed to protecting your privacy and ensuring you have a positive experience on our Website.

Website and Market orders — OÜ Robocop
Registry Code: 10038156
Registered Address: Harju maakond, Tallinn, Põhja-Tallinna linnaosa, Sõle tn 14/2, 10611, Estonia
Email: info@fitness.ee
Website: turg.fitness.ee
OÜ Robocop is the controller for the Website and, as the seller, for the order, payment and invoice records it must keep.

Fitness.ee App — Fit Labs OÜ
Registry Code: 17442328
VAT Number: EE102972984
Registered Address: Harju maakond, Tallinn, Mustamäe linnaosa, Pöörise tn 7-51, 13520, Estonia
Email: support@maxfit.ee (privacy requests: info@fitness.ee)
Fit Labs OÜ is the controller for the personal data processed in the App: the food diary and body data (health data), consent records, voice and meal photos, sign-in in the App, App usage statistics and App account deletion. Calorie tracking in the App is provided by Fit Labs OÜ's own service BurnWeek. For orders placed in the App, OÜ Robocop, as the seller, processes the order and payment data on Fit Labs OÜ's behalf.

Shared account and FitCoins: the Website and the App use one fitness.ee account and one FitCoins programme. For the account data (email, sign-in identities, profile) and the FitCoins programme, OÜ Robocop and Fit Labs OÜ are joint controllers (GDPR Art. 26). Under their arrangement, info@fitness.ee is the single contact point: you can send any request there, or to either company, and it will be handled for both.

For questions about this Privacy Policy or our data practices, please contact us at info@fitness.ee.

We have not appointed a data protection officer. All privacy questions and requests go to info@fitness.ee.

We collect the following categories of personal data:

3.1 Account Information

• Email address (required for account creation)
• Password (stored as encrypted hash)
• First name and last name
• Display name (optional)
• Profile picture (if using Google OAuth)

3.2 Order and Shipping Information

• Billing and shipping addresses
• Phone number
• Order history and purchase details
• Payment transaction records (payment card details are processed by Montonio and not stored by us)

3.3 Technical and Usage Data

• Search queries on our Website
• Recent search history (stored locally in your browser for 30 days)
• Shopping basket contents (stored locally in your browser)
• Language preference
• IP address (for security and fraud prevention)
• Browser type and user agent (for compatibility and security)

3.4 Authentication Data

• Access tokens and refresh tokens (for session management)
• OAuth account linkage (if using Google Sign-In)
• Password reset tokens (temporary, expire after 60 minutes)

We process your personal data based on the following legal grounds:

• Contract Performance (GDPR Art. 6(1)(b)): Processing necessary to fulfill your orders, manage your account, and provide customer service.
• Consent (GDPR Art. 6(1)(a)): For marketing communications, optional features, and cookies/localStorage usage (where required).
• Explicit Consent for Health Data (GDPR Art. 9(2)(a) and Art. 6(1)(a)): For the food diary and body data used for calorie tracking in the App (see section 6).
• Legal Obligation (GDPR Art. 6(1)(c)): Compliance with Estonian tax and accounting laws (7-year retention of transaction records).
• Legitimate Interests (GDPR Art. 6(1)(f)): Fraud prevention, website security, improving user experience, and search functionality optimization.

We use your personal data for the following purposes:

• Order Fulfillment: Process your orders, arrange shipping, send order confirmations and updates.
• Account Management: Create and manage your account, authenticate your identity, enable password resets. Contact information (email, phone) provided during checkout is saved to your account profile for order fulfillment and to streamline future purchases.
• Payment Processing: Process payments through Montonio (our payment processor).
• Communication: Send transactional emails (order confirmations, password resets), respond to inquiries.
• Personalization: Remember your language preference, recent searches, and shopping basket.
• Search Functionality: Provide product search with AI-enhanced results and recommendations.
• Security: Detect and prevent fraud, protect against unauthorized access, maintain platform security.
• Legal Compliance: Comply with tax, accounting, and consumer protection laws.
• Service Improvement: Analyze anonymized usage patterns to improve our Website and services.

The Fitness.ee mobile app (iOS) uses the same account as turg.fitness.ee. Fit Labs OÜ (registry code 17442328) is the controller for the personal data processed in the App; in this section "we" means Fit Labs OÜ. Market orders placed in the App are sold by OÜ Robocop (see section 2).

6.1 Food Diary and Body Data (Health Data)

If you use calorie tracking, we process the meals you log (typed text, voice recordings, meal photos, scanned barcodes), calories and nutrients, your daily goal, and the body details you enter (sex, age, height, weight, target weight). Under GDPR Article 9 this is data concerning health.

Legal basis: your explicit consent (GDPR Art. 9(2)(a) and Art. 6(1)(a)). Calorie tracking is optional; the Market, articles and rewards work without it.

Withdrawing consent: you can withdraw your consent at any time in the App (Me → Nutrition settings → Withdraw health-data consent), by writing to info@fitness.ee or by deleting your account. Calorie tracking stops immediately and the App sends nothing more to BurnWeek; we then delete your food diary and body data in BurnWeek within 30 days. Your account, orders and FitCoins are not affected. Withdrawal does not affect the lawfulness of processing before it.

Who sees it: your food diary is stored in BurnWeek, Fit Labs OÜ's own calorie-tracking service (see section 7). OÜ Robocop and the Market do not receive or use it. We never show your calories or weight to other users and never use them for advertising.

6.2 Camera, Microphone and Photos

The App asks for access to the camera, microphone and photo library only when you start logging a meal by photo, barcode or voice. Voice: the audio is streamed to OpenAI (USA) for transcription and is not stored; the transcript text is kept as part of your food diary and may also appear in BurnWeek's technical server logs. Meal photos: a photo is analysed by OpenAI (USA) vision and stored by BurnWeek in AWS (us-east-1, USA) for up to 90 days. A second copy is kept, on our instructions and only to check and improve the accuracy of meal recognition in the Service, until you delete your account or withdraw consent. When your photos are deleted, earlier stored versions may remain in the storage system for a limited time before they are purged. Backups are kept for up to 30 days. See section 7 (BurnWeek). We do not use the camera for face recognition.

6.3 Sign-In

You can sign in with a code sent to your email, with Sign in with Apple, or with Google. From Apple or Google we receive your email address (with Apple this may be a private relay address) and an account identifier. We never receive your Apple or Google password.

6.4 FitCoins, XP and the Daily Question

To run the rewards programme we process your check-ins, answers to the daily question, missions, streak, XP, FitCoin balance and redemptions (legal basis: contract, GDPR Art. 6(1)(b)). FitCoins are a discount on Market orders and have no cash value.

6.5 Data Stored on Your Phone

Your sign-in session, cart, language and App settings are kept in the App's storage on your phone. They are removed when you sign out or delete the App.

6.6 No Tracking

The App contains no advertising or analytics SDKs, does not track you across other companies' apps or websites, and does not use your device's advertising identifier.

Usage statistics. To know how many people use the App and which features they use, the App sends our own server (not a third party) a short record when you open it, switch tabs, search, view a product, add to cart or place an order. It contains only the type of action, the time, a random installation identifier created by the App, the App build, operating-system version and language, and your account if you are signed in. It does not contain what you searched for, which products you viewed or your order details. Legal basis: our legitimate interest in running and improving the App (GDPR Art. 6(1)(f)). Records are deleted after 400 days, or with your account. You can turn this off at any time in the App under Me → “Share usage statistics”; when it is off, the App sends no usage records.

6.7 Deleting Your Account

You can delete your account in the App (Me → Delete account) or by writing to info@fitness.ee. Deletion cannot be undone. We erase your email address, sign-in identities (email, Apple, Google), consent records, check-ins, answers, missions and other rewards activity; your FitCoin balance is forfeited. Bookkeeping records of FitCoin and XP movements are kept only under a random identifier that no longer links to you.

Your food diary and body data in BurnWeek are deleted within 30 days of your account deletion.

Order and payment records are kept for 7 years as required by Estonian accounting law. AI-coach plans and nutritionist bookings are not linked to the App account; we erase them on request.

We share your personal data with the following service providers and recipients:

7.1 Payment Processing

Montonio Finance OÜ (Estonia, EU)
Purpose: Process payment transactions securely (card payments, bank links, wallets)
Data shared: Billing information, payment amounts
Privacy Policy: https://montonio.com/privacy-policy/

7.2 Partner Shops

Purpose: Delivering your order — each partner shop ships its own products
Data shared: Name, delivery address or parcel locker, phone number, email address, order contents
Each shop is a separate controller for the delivery of its order.

7.3 Email Service

Amazon Web Services (AWS SES) (EU — Sweden)
Purpose: Send transactional emails (order confirmations, sign-in codes)
Data shared: Email address, name, order details
Privacy Policy: https://aws.amazon.com/privacy/

7.4 Sign-In with Google

Google LLC (United States)
Purpose: Optional sign-in with Google
Data shared: Email, name, profile picture, account identifier
Privacy Policy: https://policies.google.com/privacy

7.5 Sign in with Apple

Apple Inc. (United States)
Purpose: Optional sign-in in the App
Data shared: Email or private relay address, account identifier
Privacy Policy: https://www.apple.com/legal/privacy/

7.6 Calorie Tracking

BurnWeek (Fit Labs OÜ)
Role: BurnWeek is Fit Labs OÜ's own calorie-tracking service, not a separate company; Fit Labs OÜ provides calorie tracking in the App under the BurnWeek brand
Purpose: Storing the food diary, recognising meals from voice and photos, calculating calories and nutrients
Data shared: Account identifier, logged meals, voice recordings, meal photos, barcodes, daily goal, body details
Voice recordings: sent to OpenAI (USA) for transcription, audio not stored; the transcript is kept in the food diary and may appear in technical server logs
Meal photos: stored by BurnWeek in AWS (us-east-1, USA) for up to 90 days; a second copy for checking recognition accuracy is kept until account deletion or withdrawal of consent; earlier stored versions may remain for a limited time after deletion; backups up to 30 days
Hosting and sub-processors: application and database at Hetzner, Helsinki (Finland, EU); photo storage, backups and email via Amazon Web Services (USA); OpenAI (USA) for text, image and speech recognition; OpenFoodFacts for barcode lookups
Deletion: BurnWeek is not yet automatically connected to account deletion; on account deletion or withdrawal of consent we record the request and delete your data in BurnWeek within 30 days

7.7 Product Content Enhancement

OpenAI, Inc. (United States)
Purpose: Generate product descriptions, FAQs, and translations
Data shared: Product information only (NOT user personal data)
Note: Your personal data, search queries, and orders are NOT sent to OpenAI by us. Meal recognition in the App is performed by BurnWeek (see 7.6).
Privacy Policy: https://openai.com/privacy

7.8 Cloud Hosting

Amazon Web Services (AWS) (EU Region)
Purpose: Host our application and database
Data location: EU (Stockholm, Sweden)
Privacy Policy: https://aws.amazon.com/privacy

International Transfers: Some of our processors and sub-processors, in particular OpenAI and Amazon Web Services (used by BurnWeek), process data in the United States. We rely on the European Commission's standard contractual clauses (SCCs) and, where the provider is certified, the EU-US Data Privacy Framework as the safeguard for these transfers. You can ask for a copy of the safeguards at info@fitness.ee.

We retain your personal data for the following periods:

• Active Accounts: Indefinitely, until you delete your account or request deletion.
• Deleted Accounts: Deletion takes effect immediately, with no grace period; what is erased and what is kept is described in section 6.7. Your food diary and body data in BurnWeek are deleted within 30 days.
• Order Data: 7 years from purchase date (Estonian accounting law requirement), including the buyer and delivery details on the order; they are kept after account deletion because the law requires it.
• Payment Transactions: 7 years (tax law requirement).
• Search Query Logs: 90 days, then automatically deleted.
• Access Tokens: 15 minutes (automatic expiry).
• Refresh Tokens: 7 days (automatic expiry).
• Password Reset Tokens: 60 minutes (automatic expiry).
• Browser Storage (localStorage/sessionStorage): Recent searches expire after 30 days; basket persists until you clear it.

What you can control yourself, in one place. Details are in sections 6 and 9; any request can also go to info@fitness.ee and is answered within one month.

• Download your data: your food diary as a CSV file in the App (Track → “Powered by BurnWeek” → Download my food log); your account data in JSON from your turg.fitness.ee account settings; or ask info@fitness.ee for a full copy.
• Delete your account: in the App (Me → Delete account) or by writing to info@fitness.ee. What is erased and what the law makes us keep is in section 6.7.
• Health-data consent: withdraw it in the App (Me → Nutrition settings → Withdraw health-data consent). Calorie tracking stops at once and your food diary is deleted within 30 days.
• Usage statistics: switch off Me → “Share usage statistics”; the App then sends no usage records.
• Camera and microphone: the App asks only when you start a photo, barcode or voice log; change it anytime in iOS Settings → Fitness.ee.
• Marketing emails: use the unsubscribe link in any email or your account settings.
• Advertising and tracking: there is nothing to opt out of: the App has no ads and does not track you across other companies' apps or websites (section 6.6).
• Correction, restriction, objection, complaint: see section 9.

You have the following rights regarding your personal data:

9.1 Right of Access (Art. 15)

You can download all your personal data in JSON format from your account settings. Your food diary and body data are held in BurnWeek; to get a copy, write to info@fitness.ee and we will send it to you within one month.

9.2 Right to Rectification (Art. 16)

You can update your profile information, addresses, and preferences at any time in your account settings.

9.3 Right to Erasure / "Right to be Forgotten" (Art. 17)

You can delete your account in the App (Me → Delete account) or by writing to info@fitness.ee. What is erased and what is kept is described in section 6.7. Order records are retained for legal compliance (7 years). Your food diary and body data in BurnWeek are erased within 30 days (see 7.6).

9.4 Right to Data Portability (Art. 20)

You can download your data in a structured, machine-readable format (JSON) from your account settings.

9.5 Right to Object (Art. 21)

You can object to processing based on legitimate interests by contacting info@fitness.ee.

9.6 Right to Restrict Processing (Art. 18)

You can request restriction of processing by contacting info@fitness.ee.

9.7 Right to Withdraw Consent

You can withdraw consent for marketing communications or optional features at any time in your account settings. You can withdraw health-data consent in the App (Me → Nutrition settings) and turn off usage statistics under Me → “Share usage statistics”. Withdrawal does not affect processing before it.

9.8 Right to Lodge a Complaint

You have the right to lodge a complaint with the Estonian Data Protection Inspectorate:
Andmekaitse Inspektsioon
Email: info@aki.ee
Website: www.aki.ee

We use a small number of first-party cookies on the fitness.ee domain (your sign-in session, your consent choices and, only with your analytics consent, an analytics session identifier), together with browser localStorage and sessionStorage:

• Essential (Required): Authentication tokens (accessToken, refreshToken) to keep you logged in.
• Functional (Optional with consent):
  • Language preference (localStorage)
  • Shopping basket (localStorage)
  • Recent searches (localStorage, expires after 30 days)

10.1 Session Recordings

With your analytics consent, we record limited on-page interactions (clicks, scrolls, page transitions, form field focus and blur events) across our site, after you grant Analytics consent in the cookie banner, so we can diagnose technical issues and improve the shopping experience. We do this using open-source software (rrweb) hosted on our own EU servers — no third-party analytics provider receives this data.

What we never record:

• The contents of any form field — email, name, phone, address, notes, etc. are always masked as asterisks in the recording.
• Payment card or bank details — these are entered into isolated isolated payment widgets (Montonio) that we cannot see into.
• Interactions before you grant consent — the recorder does not start, and no rrweb code is loaded, until you accept the Analytics toggle.

Storage and retention: Recordings are stored encrypted in our EU cloud infrastructure, retained for 90 days, and then automatically deleted. Access is restricted to authorised staff for debugging purposes only.

Legal basis: Your consent (GDPR Art. 6(1)(a)), given via the "Analytics" toggle in the cookie banner. You can withdraw consent at any time by revoking analytics consent in the cookie banner; future recordings will stop, and if you want past recordings deleted sooner than the 90-day cycle, contact info@fitness.ee.

You can manage your preferences in the cookie consent banner that appears on your first visit. You can withdraw consent at any time by clearing your browser's localStorage.

We implement industry-standard security measures to protect your personal data:

• Encryption: All data in transit is encrypted using HTTPS/TLS. Passwords are hashed using BCrypt (strength 10).
• Access Controls: Role-based access control (RBAC) limits who can access your data.
• Authentication: Secure JWT-based authentication with short-lived tokens (15 min access, 7 day refresh).
• Tokenization: Payment card data is processed by Montonio; we never store full card numbers.
• Monitoring: Continuous security monitoring and logging to detect unauthorized access.
• Regular Audits: Regular security audits and penetration testing.

While we take all reasonable precautions, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.

In the event of a data breach that may adversely affect your rights and freedoms, we will:

• Notify the Estonian Data Protection Inspectorate within 72 hours (GDPR Art. 33)
• Notify affected users without undue delay if the breach poses a high risk (GDPR Art. 34)
• Provide information about the nature of the breach, potential consequences, and mitigation measures

Our Website and the App are not intended for children under 16 years of age. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact info@fitness.ee, and we will delete it promptly.

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated policy on this page
• Updating the "Last Updated" date
• Sending an email notification for significant changes (if you have an account)

If a change requires your consent (for example a new use of your health data), we will ask for it again in the App before the change applies to you.

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

OÜ Robocop (Website and Market orders)
Email: info@fitness.ee
Website: turg.fitness.ee
Address: Harju maakond, Tallinn, Põhja-Tallinna linnaosa, Sõle tn 14/2, 10611, Estonia

Fit Labs OÜ (Fitness.ee App), registry code 17442328
Email: support@maxfit.ee (privacy requests: info@fitness.ee)
Address: Harju maakond, Tallinn, Mustamäe linnaosa, Pöörise tn 7-51, 13520, Estonia