App Privacy Policy

1. Who we are

WITU Corp, principal address 8 The Green STE A, Dover, DE 19901, develops the WitU mobile app and the WITU Band PRO bracelet and WITU Ring — wearable devices that help you understand your own physical condition. “WitU” and “we” below mean the Operator.

2. What data we collect

We collect the following data.

2.1 Account data

The app has no password: you sign in with a one-time code sent to the contact details you give us. Your account holds:

• Your name.
• Your email address or phone number — used to send the one-time sign-in code.
• Your date of birth, sex, height and weight.
• The goals, limits and preferences you enter in the questionnaire.
• The weekly activity volume you plan.

2.2 Health and activity data

• Heart rate variability (HRV, measured as RMSSD).
• Heart rate, including resting and maximum heart rate.
• Sleep duration and sleep stages.
• Steps and calories burned.
• Workouts: type, duration, heart rate, time in heart-rate zones, distance, perceived exertion and notes.
• Recovery and VO₂max test results.
• Meals, with their calorie count and macronutrients, and the water you drink.
• Your daily journal entries.

2.3 Wearable device data

If you have paired a WITU bracelet or ring: the device's hardware address, its name, its battery level and its firmware version.

2.4 Technical data

We receive the app version, your device model and your operating-system version.

Diagnostic records and crash reports stay on your device and are not sent to us. The app uses no third-party analytics or crash-reporting services.

3. How we use the data

We do not use your data for advertising, or to profile you for advertising purposes. We use it to:

• Calculate Recovery, HRV trends, VO₂max, heart-rate zones and your other metrics.
• Build your personal plan and recommendations.
• Synchronize your data between your devices.
• Answer the questions you send to support.

4. Who we share data with

We do not sell your personal data and we do not pass it to third parties for marketing purposes. It does not go to advertising networks or data brokers.

We use a single processor: Fly.io, the cloud host our server runs on. The primary hosting region is Amsterdam, the Netherlands (European Union).

We disclose data to public authorities only in response to a lawful demand.

5. Apple Health and Health Connect

If you grant permission, WitU reads the following from Apple Health (on iPhone) or Health Connect (on Android): sleep, heart rate, heart rate variability, resting heart rate, steps, active calories, VO₂max, respiratory rate, water and nutrition.

WitU can write the following back: completed workouts, active calories, distance, VO₂max, water and nutrition.

Data from Apple Health and Health Connect is not used for advertising and is not passed to third parties. You can withdraw the permission at any time in your phone's system settings.

6. Bluetooth and location

Bluetooth is used solely to communicate with your WITU bracelet or ring.

The app does not collect or store your location. On Android 12 and later, the permission to find nearby devices is declared with the flag stating that it is never used to derive location. On Android 8 through 11, the operating system requires the location permission in order to scan for Bluetooth devices at all — without it, the phone cannot find the bracelet. We ask for it for that reason alone and never access your coordinates.

7. Storage

Data is stored locally on your device and on our servers for synchronization. It is transmitted over a secure HTTPS connection.

We keep it for as long as your account is active. After you delete your account, the data is erased within 30 days.

On Android, Google cloud backup is disabled for the app: the health database is not included in the device's backups.

8. Your rights

• Access. To request a copy of your data, write to support@witu.health.
• Correction. Change your details in the Profile section.
• Deleting your account. Settings → Delete account erases the data both on the device and on the server.
• Export. Settings → Export data.
• Withdrawing consent. Turn off access to Apple Health or Health Connect in your phone's system settings; unpair the wearable device in the app.

9. Security

• All network requests run over HTTPS.
• Access tokens are held in the platform's secure store: Keychain on iOS, EncryptedSharedPreferences on Android.
• Access to data on the server is restricted and accessible only with your account's access token.
• Cloud backup of the app is disabled on Android.

10. Children

WitU is not intended for anyone under [AGE]. We do not knowingly collect data from minors.

11. For users in the European Union

We act as a data controller within the meaning of the GDPR. Health data is a special category of personal data (Article 9 GDPR) and is processed on the basis of your explicit consent, which you may withdraw at any time.

You have the rights of access, rectification, erasure, restriction of processing, portability and objection to processing. Send requests to support@witu.health. You also have the right to lodge a complaint with the supervisory authority in your country.

12. For users in the United Arab Emirates

Processing is carried out in accordance with UAE Federal Law No. 45 of 2021 on the Protection of Personal Data. Because the server is located in the European Union, processing involves a cross-border transfer of data, to which you consent by using the app.

13. For users in Russia

Personal data is processed with the data subject's consent, in accordance with Federal Law No. 152-FZ “On Personal Data”.

Please note: our servers are located outside the Russian Federation.

14. For users in the United States

We do not sell personal data and we do not share it for targeted advertising within the meaning of the CCPA/CPRA.

You have the right to request details of the data collected about you and to have it deleted — support@witu.health. We do not deny service to anyone for exercising these rights.

15. Changes

We may update this Policy. We give notice of material changes in the app at least 30 days before they take effect.

16. Contact

This document is a template prepared for WITU Corp and should be reviewed by an attorney and adapted to applicable law before publication. It is provided for information only and is not legal advice.

• Support: support@witu.health
• Privacy questions: support@witu.health