# Privacy policy

> The health and training data Stronge processes, the lawful basis for it, who processes it, how long it is kept, and how to export or delete everything.

Source: https://stronge.app/privacy

Effective 14 September 2026. Chutta Digital (Pty) Ltd.

## 01. Who we are and what this policy covers

Chutta Digital (Pty) Ltd (“Stronge”, “we”, “us”) makes the Stronge mobile app and this website. We are the **responsible party** under South Africa’s Protection of Personal Information Act, 2013 (POPIA) and the **data controller** under the UK and EU General Data Protection Regulation (GDPR) for the personal information described in this policy.

Our registered address is 213 Main Road, Three Anchor Bay, Cape Town, 8005. Our Information Officer is Reegan Alward, who can be reached at [support@stronge.app](mailto:support@stronge.app).

This policy applies to the Stronge mobile app and to stronge.app. It explains what we collect, why, what we do not collect, who processes it on our behalf, how long we keep it, and the rights you have over it.

**It describes what happens to your information, not how Stronge is built.** Where a section says what we do with something, that is the commitment we are making and the one you can hold us to; the internal workings behind it are our own and are deliberately not set out here. That is not a limit on your rights. If you want more detail about how any of this works in your particular case — to exercise a right, to satisfy yourself about something, or because you are advising someone who uses Stronge — email our Information Officer at [support@stronge.app](mailto:support@stronge.app) and ask. We answer. Where this policy says “health data” it means information about your body and your training, such as your injury history, pain reports, body weight, biological sex, date of birth and workout summaries. It covers anything of that kind we hold, whether or not it is listed here. POPIA calls this _special personal information_; GDPR calls it _special category data_. Both give it extra protection, and [section 5](#health-data) sets out the basis on which we handle it.

## 02. The personal information we collect

Everything described in this section is linked to your account. Where we measure how stronge.app itself is used, that may be counted in aggregate without being linked to anyone, and we say so rather than describing account-linked information as anonymous.

### Information you give us

- **Account details**: your email address, your name, and the identifier your sign-in provider gives us if you use Sign in with Apple or Google.
- **Your profile**: date of birth, biological sex and body weight. These set your starting loads and your age eligibility; they are not optional, because prescribing load without them would be guessing.
- **Injury history and status**: what you are managing, what you have cleared, and the rehab stage you are at for each.
- **Pain and soreness reports**: the flags you raise on a movement and the soreness and energy ratings you give before a session.
- **Training context**: your sport, weekly volume, the equipment you have, your session-length range, your goals and any race date you add.
- **Free text you write**: notes on an exercise, notes for your physio, and any feedback you send us.

### Information from Apple Health or Health Connect

Only if you grant that permission, and only the types we ask for. Your device shows you the exact list at the moment it asks, and that prompt is the authoritative version: we cannot read a type you have not granted. What we ask for is the training and body information the engine needs to prescribe load safely, such as your workouts, heart rate, body weight, date of birth and biological sex.

What we then store is narrower than what we read. From your workouts we keep **summaries** rather than the full detail we are given, today at weekly level: things like session count, distance, duration and elevation. Your heart rate is handled differently and [section 3](#what-we-do-not-collect) explains how. You can decline this permission entirely and enter your training by hand instead; the app works either way.

### Information Stronge generates as you use it

- The sessions prescribed to you, what you completed, and the loads you logged.
- Workouts you pinned, exercises you swapped, and the progression events those earned.
- A record of what you were given and why, which is what lets the app tell you the reason a given exercise is in your session.

### If you join the Beta Team on this website

You do not need an account to give us your email address on stronge.app. When you do, we store the address, which part of the site you submitted it from, and the country your request came from, and we take you straight to a few questions about your training, at a private link.

If you answer them, we also store your name, the email address your Apple Account uses, whether you run or ride and roughly how often, what you currently do for strength work, which training devices or services you use, how you heard about us, and what you tell us in your own words about why Stronge would suit you. We record that you confirmed the two boxes on that page, because we have to be able to show your consent was given.

Sending your answers emails you the install link. That link is TestFlight’s own public link for the beta, so installing goes through Apple on Apple’s terms, as it would for any TestFlight tester — but we do not pass your Apple Account address to Apple to do it. We keep that address so we can find you in TestFlight if the app will not install for you; nothing is sent to it.

Until 8 September 2026 we did register that address with Apple as a named tester at submission. If you applied before then, Apple holds it under its own terms, and asking us to delete your application also removes that tester.

If you give us the same email address again later, we send you straight to the install link rather than asking the questions again. Your answers are not shown.

**Those questions deliberately do not ask about your injuries, pain, surgeries or medication.** The app asks what it needs to, in setup, where it is actually used. Nothing collected on this website is health data, unless you choose to write about your health in the free-text box, which you do not need to do.

All of it is held separately from the app’s own records. Ask us to remove it and we will.

### If you use the contact form on this website

The name, email address and message you type are sent to a private messaging channel our team monitors, which is how we see and reply to it. This is an ordinary “get in touch” form: unless you choose to write about your health in the message itself, nothing you send here is health data. That channel is a processor for this purpose only, named again in [section 9](#processors), and we do not control how long it retains a delivered message, so please do not put anything in the message you would not want sitting in a chat log indefinitely. Email [support@stronge.app](mailto:support@stronge.app) directly if that matters to you.

### Information collected automatically

- **Product usage events**: which screens and features you use. This is **off unless you turn it on**, and it is **linked to your account**. We do not describe it as anonymous, because it is not.
- **Crash and error messages**: so we can fix what broke.

## 03. What we do not collect

These are commitments, not aspirations. We hold ourselves to them in how the app is built, not by policy alone, and [section 19](#changes) governs what happens if any of them ever has to change.

- **Your location, and your GPS routes.** Never read, never stored. Location is not in the set of data types Stronge requests from Apple Health, so there is nothing to store. Stronge knows you ran for 48 minutes. It does not know where.
- **Your raw heart rate.** Your heart-rate trace is read on your phone and reduced there to a single summary figure for the week. Only that figure is sent to us; the trace itself never leaves the device.
- **Advertising identifiers, and tracking for advertising.** No IDFA and no advertising SDKs. We do not track you across other apps or websites, we do not build advertising profiles, and we do not pass your information to advertising networks or data brokers. Any measurement we do is about how Stronge itself is used, on the basis described in [section 6](#consents), and never for advertising.
- **Payment card details.** Stronge does not process card data. If and when paid subscriptions launch, they run through Apple’s and Google’s in-app purchase systems and we never see the card.
- **Your contacts, photos, microphone or calendar.**

**One clarification, because the distinction matters and is easy to over-read.** The heart-rate and location commitments above are specific to heart rate and location. They do not extend to everything else. Your date of birth, biological sex, body weight, injury history, pain reports and completed sessions _are_ stored on our servers, because the engine that writes your plan runs there. Any statement that “your data stays on your device” would be untrue of those, and we do not make it.

## 04. Why we process your information, and on what basis

We process personal information for the purposes below and no others. POPIA requires that processing be lawful and minimal (sections 9 to 11); GDPR requires a lawful basis under Article 6, and a further condition under Article 9 for health data.

- **To give you the service you signed up for**: creating your account, authenticating you, writing and adapting your sessions, showing your progress and keeping your plan in step with your training. _Basis:_ performance of our contract with you (POPIA s11(1)(b); GDPR Art 6(1)(b)).
- **To handle your health data safely**: your injury history, pain reports, body metrics and workout summaries drive which exercises you are given and, more importantly, which ones you are never given. _Basis:_ your explicit consent (POPIA s27(1)(a); GDPR Art 6(1)(a) and Art 9(2)(a)). See [section 5](#health-data).
- **To understand which features work**: product usage events. _Basis:_ your consent, given separately and off by default (POPIA s11(1)(a); GDPR Art 6(1)(a)).
- **To improve the training engine**: a separate, optional research use described in [section 7](#engine-and-ai). _Basis:_ your separate explicit consent, off by default (POPIA s27(1)(a); GDPR Art 9(2)(a)).
- **To keep the service secure and working**: crash reports, abuse prevention, debugging. _Basis:_ our legitimate interests in a functioning, secure product, balanced against your rights (GDPR Art 6(1)(f); POPIA s11(1)(f)).
- **To meet legal obligations**: where a law, regulator or valid court order requires it. _Basis:_ legal obligation (GDPR Art 6(1)(c); POPIA s11(1)(c)).

We do not use your health data for advertising or marketing. We do not profile you for advertising at all.

## 05. Health data, and why we ask for consent

POPIA section 26 prohibits processing information about a person’s health unless a specific exception applies. GDPR Article 9 does the same. In both cases the exception we rely on is your **explicit consent**: POPIA s27(1)(a) and GDPR Art 9(2)(a).

That is why the consent to process your training and profile data is presented as a required consent at sign-up rather than buried in terms you scroll past. Stronge cannot function without it: an engine that does not know your injury history cannot avoid the movements that would aggravate it.

You can withdraw that consent at any time. Because it is the basis on which the whole service operates, withdrawing it means the app can no longer build your sessions, so the practical way to end all processing is to delete your account, which is one action inside the app (or on stronge.app if you no longer have it) and is covered in [section 13](#export-and-deletion). Withdrawing consent does not affect the lawfulness of anything we did before you withdrew it.

## 06. Your consents, and how to change them

Stronge keeps separate consents rather than one blanket agreement. Each is recorded with a version and a timestamp, and every change is appended as a new record, so there is a full history of what you agreed to and when. You can view and change them at any time in the app’s privacy settings.

- **Process my training and profile data.** Required. Lets Stronge use your workouts, injury history, date of birth and biological sex to build and safely tailor your sessions.
- **Read from Apple Health or Health Connect.** Optional, and off until you grant it. Without it you enter your training manually.
- **Share product usage data.** Optional, off by default. Records which screens and features you use, linked to your account. Never used for advertising, and no advertising SDK is involved. The entire app works with this off.
- **Help improve the training engine.** Optional, off by default, and described in [section 7](#engine-and-ai). **Switching it off deletes everything already collected under it**, at the moment you revoke it and not later.

## 07. How your plan is generated, and where AI is involved

### The engine

Your sessions are produced automatically. The engine works from the information described in [section 2](#what-we-collect) — your profile, your injury status, your recent training load, your equipment and the time you have — and chooses what you are given and how much of it. Safety constraints take precedence over every other consideration, so a movement that is contraindicated for an injury you have declared is never selected.

This is automated processing, and we want to be plain about its limits. It is training decision support, not a decision that produces legal or similarly significant effects for you. You can swap any exercise, flag anything that hurts, change the session, or ignore it. You can also ask us how a decision was reached. See [section 16](#your-rights).

### Where a language model is used

A language model writes some of the explanatory text you read in the app. **It does not choose your exercises or your loads**, and it is constrained so that it cannot introduce a number, an exercise or a claim that is not already in the information given to it.

It runs on infrastructure operated by a processor on our documented instructions, with logging of the content of those requests switched off. What is put in front of it is training context only, and it does not include your name, email address or date of birth. Introducing a new processor is a material change, so if the provider running it changes, [section 19](#changes) applies and we will tell you before it takes effect.

### The research use, if you opt in

If you turn on “Help improve the training engine”, we keep a copy of your sessions and how they went, under a random identifier, with your age and weight recorded in broad bands rather than as exact values, and with your name, exact date of birth and free-text notes excluded by construction.

We describe this data as **pseudonymised**, not anonymised. That is a deliberate choice of word: pseudonymised data remains personal information under both POPIA and GDPR and keeps the full set of protections in this policy. We will not call it anonymous unless and until we can demonstrate that it is.

## 08. The lab report

Stronge can render your pain history, injury and rehab state, exercise log and weekly load into a PDF intended for a physiotherapist or clinician.

That document is composed **on your device**, from information the app already holds and you can already see. Nothing is uploaded to us to produce it, and no recipient is pre-set. The file is handed to your phone’s share sheet and where it goes next is your instruction, not ours. It is not a disclosure by us and we have no record of who you sent it to.

The report states on its face that its contents are self-reported and are not a clinical record, so that a clinician reading it does not mistake it for a validated measurement.

## 09. Who else processes your information

We use service providers to run Stronge. They are **operators** under POPIA and **processors** under GDPR, which means they act only on our documented instructions and never for their own purposes. They are not recipients we have shared your data with in any commercial sense.

- **Cloud hosting, authentication and database.** Your data is stored in the United Kingdom.
- **Content delivery and AI processing.** Delivery of this website and the application store behind it, delivery of exercise demo videos and images, and the AI text generation described in [section 7](#engine-and-ai).
- **An email delivery provider**: the emails this website sends you — the welcome with your install link, when you finish the questions, and, if you ask to delete your account here, the confirmation link and the note that it is done. It processes your email address and the contents of that message on our instructions, and may do so outside the UK.
- **Apple and Google**: sign-in, and app distribution. If paid subscriptions launch, their in-app purchase systems handle payment; we never receive card details.
- **A private messaging channel**: only if you use the contact form on this website. Your name, email and message are delivered there so our team can reply, and that provider may process them outside the UK. [Section 11](#storage-and-transfers) explains how transfers are covered.

Beyond these, your information is not given to anyone. In particular there are no advertising networks and no data brokers in the app or on this site.

This list describes the providers we use today. If we add one, such as a product analytics provider for the usage events described in [section 6](#consents), it will appear on this list before it begins processing anything, and [section 19](#changes) sets out the notice you get first.

## 10. We never sell your information

We do not sell your personal information, and we do not trade or barter it. We have never done so.

We do not share it with **insurers, medical schemes, employers or advertisers**, and we will not. This is not a limitation of our current business model, it is a commitment about the product.

We would disclose information only where we are legally compelled to: a valid court order, a legal obligation, or to establish or defend a legal claim. Where the law permits us to tell you that this has happened, we will.

If Stronge is ever acquired or merged, your information could transfer to the acquiring entity as part of that transaction. It would remain subject to this policy, and we would tell you before it changed hands.

## 11. Where your information is stored, and cross-border transfers

Your data is stored in the **United Kingdom**, encrypted in transit and at rest. If we ever move or add a storage region, that is a material change under [section 19](#changes): we will tell you before it happens and this section will say where your data is.

**If you are in South Africa.** This is a cross-border transfer under POPIA section 72. It is permitted because the United Kingdom, through the UK GDPR and the Data Protection Act 2018, subjects the recipient to a law that upholds principles for the lawful processing of personal information substantially similar to POPIA’s, including provisions on onward transfer.

**If you are in the UK or the EEA.** Your data is processed within the UK, which benefits from a European Commission adequacy decision, so transfers from the EEA require no additional safeguards. If that adequacy decision lapses or is withdrawn, we will put an appropriate safeguard in place and update this policy.

**One exception worth naming.** The AI text generation described in [section 7](#engine-and-ai) may be processed outside the UK. Those requests carry training context and no direct identifiers, and logging of their content is off.

**A second exception.** If you use the contact form on stronge.app, that message is delivered to a messaging provider outside the UK, as described in [section 9](#processors), and it is delivered there only because you chose to send it. Where a transfer of this kind is not covered by an adequacy decision, we rely on the standard contractual clauses or another transfer mechanism the law permits.

## 12. How long we keep your information

We keep personal information only as long as the purpose it was collected for requires: POPIA section 14 and GDPR Article 5(1)(e).

- **Your account and training history**: for as long as your account exists. Your history is the thing that makes the plan get better, so we do not prune it while you are using Stronge.
- **Product usage events**: kept only while they are useful for understanding how features are used, then deleted.
- **The health information behind a session we generated**: cleared once support and debugging no longer need it. The record of what you were given is kept, because it is what lets the app explain itself; the underlying health signals are erased.
- **Changes you make to a session**: kept while they are still relevant to your plan, then deleted.
- **Research data, if you opted in**: kept while that consent stands, and deleted immediately when you withdraw it. If you delete your account without withdrawing it first, the link between you and that data is removed and the data itself is kept. See [section 13](#export-and-deletion).
- **Data exports you generate**: the download link is short-lived and the file is swept automatically.
- **Your Beta Team answers**: until Stronge opens to you and you either create an account or ask us to remove them. The private link stops working after a limited period, and we only ever store a one-way fingerprint of it, never the link itself.
- **A contact form message**: we don’t set a retention period on the private channel it lands in. Don’t put anything in it you wouldn’t want kept indefinitely.

These are the criteria we apply rather than dates you have to hold us to. We would rather state a rule we keep than a number that drifts. Ask us at [support@stronge.app](mailto:support@stronge.app) what a current period is and we will tell you. When you delete your account, it all goes at once, with the exceptions set out in [section 13](#export-and-deletion).

## 13. Getting your data out, and deleting it

Both are in the app, in its privacy settings. Neither requires you to email us and wait. If you no longer have the app, you can delete your account at [stronge.app/delete-account](https://stronge.app/delete-account): we email the address on your account a link that works once, and opening it lets you confirm.

**Export.** Stronge produces a machine-readable file containing all of the personal information we hold about you, wherever we hold it, and gives you a private, short-lived link to download it. This is your right of access and your right to portability in one action.

**Deletion.** Deleting your account, by either route, removes your data wherever we hold it, with the two exceptions below: profile, injuries, sessions, completions, notes, consents, usage events, data exports, and our record of your subscription. It also revokes the sign-in token if you used Sign in with Apple. It is not a marker that leaves your data in place.

Two things outlast it. **Research data**, if you had “Help improve the training engine” switched on: deleting your account removes the only link between you and that data, and the data itself is kept. We do not describe what remains as anonymous, so if you want it deleted outright, switch that setting off before you delete your account — that deletes it immediately. And **statistics that carry no identifier**, such as totals across many athletes, are kept.

Treat deletion as permanent: if we ever offer a short window to change your mind, the app will say so plainly at the point you delete, and anything not recovered in that window is gone for good.

Where the law requires us to keep a specific record despite a deletion request, we will keep only that record, only for as long as required, and we will tell you what it is.

## 14. Security

Your information is encrypted in transit and at rest. Every record is tied to the account that owns it, and that isolation is enforced below the application, so your data is readable only by your authenticated account. Access to production by us is limited to the people who need it.

The absence of advertising SDKs and data brokers is itself a security property: the smaller the number of parties holding your health data, the smaller the number of ways it can leak. We keep that number to what the product genuinely needs.

No system is perfectly secure and we will not claim otherwise. Keep your account credentials to yourself, and tell us at [support@stronge.app](mailto:support@stronge.app) if you think your account has been compromised.

## 15. If there is a security breach

If personal information is accessed or acquired by an unauthorised person, we will notify the **Information Regulator of South Africa** and affected users as soon as reasonably possible, as POPIA section 22 requires. Where UK or EU GDPR applies we will notify the relevant supervisory authority within **72 hours** of becoming aware, and notify you directly where the breach is likely to result in a high risk to your rights.

Notification will describe what happened, what information was involved, what we have done about it, and what you can do.

## 16. Your rights

Under POPIA (sections 23 to 25) and GDPR (Articles 15 to 22) you have the right to:

- **Know what we hold and get a copy of it**: the in-app export does this immediately.
- **Have it corrected** if it is inaccurate, and completed if it is incomplete. Most of it you can edit directly in the app.
- **Have it deleted**: the in-app account deletion does this, and so does [stronge.app/delete-account](https://stronge.app/delete-account) if you no longer have the app.
- **Take it with you** in a structured, commonly used, machine-readable format.
- **Object to processing** based on our legitimate interests, and to withdraw any consent you have given.
- **Ask us to restrict processing** while a dispute about accuracy or lawfulness is resolved.
- **Not be subject to a decision based solely on automated processing** that produces legal or similarly significant effects. [Section 7](#engine-and-ai) explains why we do not consider your training plan to be such a decision, but you can always ask us how a plan was arrived at, and you can override any part of it.
- **Complain** to a regulator. See [section 20](#contact).

To exercise a right that is not already a button in the app, email [support@stronge.app](mailto:support@stronge.app). We will respond within **one month**, as the law requires, and will tell you if we need longer and why. We may need to verify your identity before acting, and we will not ask for more information than that verification needs. Exercising any of these rights is free, and we will not treat you differently for it.

## 17. Age

Stronge is for adults. You must be **18 or older** to create an account, and we check that when you create one. The threshold reflects POPIA section 34, which restricts the processing of children’s personal information.

We do not knowingly collect information from anyone under 18. If we learn that we have, we will delete it. If you believe a minor has created an account, tell us at [support@stronge.app](mailto:support@stronge.app).

## 18. Stronge is not medical advice

Stronge is strength and conditioning software that adapts to your training load. It is **not a medical device**. It does not diagnose, treat, or claim to prevent disease or injury, and nothing in it is a substitute for advice from a qualified healthcare professional.

Your injury history drives exercise _selection_: which movements you are given and which you are never given. It is not a clinical assessment. If you are injured or in pain, see a physiotherapist or a doctor. Stronge is built to work alongside them, not instead of them.

## 19. Changes to this policy

We will update this policy when what we do changes. The effective date at the top of the page always reflects the current version.

If a change is material (a new category of information, a new purpose, or a new processor), we will tell you in the app or by email **before it takes effect**, and where the change requires your consent we will ask for it rather than assume it from your continued use.

## 20. Contact and complaints

For anything in this policy, to exercise a right, or to raise a concern, email our Information Officer at [support@stronge.app](mailto:support@stronge.app). We would genuinely rather hear from you first and put something right.

That includes detail this policy does not go into. It is written to tell you what happens to your information rather than how the product is built, so if you need to go further than it does — a specific retention period, exactly what a given consent covers, what we hold about you and why — ask, and we will tell you.

You also have the right to complain to a regulator directly, and you do not have to come to us first.

- **South Africa**: the Information Regulator, [inforegulator.org.za](https://inforegulator.org.za).
- **United Kingdom**: the Information Commissioner’s Office, [ico.org.uk](https://ico.org.uk).
- **EEA**: the supervisory authority in the country where you live or work.