Privacy Policy - Holymp

Version: 2.4 · Last updated: October 5, 2026

This policy explains how personal data is processed when you use the Holymp app.

1) Data Controller

The Data Controller is:

Full name: Gabriele Vaccargiu
Service trade name: Holymp
Contact location: Parma, Italy
Privacy and data protection email: privacy@holymp.app

2) Scope

This policy applies to the Holymp mobile app and the connected backend services, including authentication, data synchronization, AI features, premium management, and optional integrations enabled by the user.

3) Categories of Data Processed

Depending on the features used, Holymp may process the following categories of data.

3.1 Account and Authentication Data

Email.
Authentication credentials managed with technical measures designed to protect their confidentiality and security.
Authentication/session tokens.
Technical data for password recovery, including OTP codes, expiry times, attempts, and technical metadata.
Google Sign-In data, if used, such as email and profile name.

3.2 Profile and Wellness Data

Profile data entered by the user, such as display name, sex, height, full date of birth, goals, and training focus.
Weight and weight history.
Integration or questionnaire parameters and preferences, such as available days, goals, level, any declared limitations/injuries, and notes.

3.2bis AI Coach Nutrition (Beta)

AI Coach Nutrition is a Beta feature, reserved for adult Premium users. If you use it we process your answers to the questionnaire, such as food preferences and exclusions and, if you choose to provide it, health information such as allergies and health conditions, and the meal plan that is generated.

We process health information only with your explicit consent (Article 9(2)(a) GDPR). You can decline by skipping the health questions, and you can withdraw consent at any time from Settings > Premium > AI Coach > Nutrition, “Your health data” card: withdrawal deletes the health data you provided and the plans built on it. We keep this data for at most 12 months without use of AI Coach Nutrition, or 30 days after Premium ends.

To generate the plan we use OpenAI (United States), which acts as our data processor. The provider receives only constraints derived in code form (for example food groups or allergens to exclude), food preferences and filtered free-text notes. It does not receive your name, your email, the name of any health condition or medication, or the result of any screening.

AI Coach Nutrition is not a doctor or a dietitian: it does not diagnose and does not prescribe therapeutic diets.

3.2ter AI Coach Chat (Beta)

When you use the Chat with the Coach we process: the text of your questions and answers, your conversation history, a short memory of non-health facts you told it (for example schedule preferences), your ratings (thumbs up/down) and the technical details of the request (tier, model used, cost, outcome).

If you are Premium, at least 18 and give your consent, to answer questions about your data the Coach reads from the app, read-only and only when you ask a question, the information needed: profile and goals, weight, meal log and food quality, workouts and programme, Health Connect data (steps, sleep, resting heart rate, variability), estimated metabolism, recovery plan, recaps and, if present, the AI Coach nutrition plan. Some of this information concerns health and wellbeing: we process it only with your explicit consent (Article 9(2)(a) GDPR), which you can give or withdraw at any time in the Coach privacy screen, which opens from the icon at the top of the Chat. Without consent the Coach only answers general questions and questions about using the app. For users aged 14 to 17 the Chat never reads personal app data: it only answers general questions and questions about using the app.

We never send the provider your name, email, password or access tokens. The Chat never writes to your account on its own: it performs an action (for example changing language or target weight) only after your confirmation, using the same functions you would use by hand.

The Chat is not a doctor and does not diagnose or prescribe treatment; for symptoms, pain or health conditions it asks you to see a professional.

Feedback. If you tap thumbs up or down we record the rating and the reason you pick. Only if you gave the optional authorisation, we also keep a copy of the question, answer and essential technical context (and any comment) and have Holymp’s authorised team review it to find mistakes and improve the app. The copy is prepared without your name, email or any link visible to your account and is accessible only to the authorised team. Without the authorisation the thumbs only record rating and reason, without the conversation text. Do not write names, contact details or unnecessary health data in the comment.

Provider. For the Chat we use Anthropic (Claude), based in the United States, which acts as our data processor.

3.3 Workout and Nutrition Data

Workout sessions, exercises, sets, repetitions, loads, RPE, timers, and notes.
Meal, food, macro, nutrition settings, and daily context data, such as short sleep, meal out, or sensitive cycle if entered.
Data used for summaries, suggestions, and workout plan optimization.

3.4 Health Connect Data

Only with the user’s consent and authorization, Holymp may read the following data from Health Connect:

steps;
sleep data;
exercise/workout data;
distance.

This data is used for fitness/wellness summaries, activity analysis, personalized suggestions, and improvement of the user experience. Holymp uses this data only to provide features requested by the user in the fitness/wellness context.

Only if the user separately turns on the optional “Recovery signals” feature (Settings > General > Health connection), Holymp additionally reads from Health Connect:

resting heart rate;
heart rate variability (HRV).

These two data types are used to show the user their own last-7-day average next to their personal reference from the previous 14 days. They are descriptive values: not a medical assessment, no scores or diagnoses, and they do not change workouts, meal plans or targets. The samples read are synced to Holymp’s servers to keep the user’s personal history and to evaluate internally, with no effect on the user, future recovery features; they are deleted with the account. The permission is separate from steps, sleep, exercise and distance and can be revoked at any time without losing the connection.

The user can revoke Health Connect permissions at any time from Android settings or from the Health Connect app. Revocation may make some personalized features unavailable or less accurate.

3.5 Photos, Videos, Files, Images, and Voluntary Attachments

Access to photos, videos, images, media, or files is optional, initiated by the user, and limited to features where the user explicitly chooses to capture or upload content.

Examples:

meal photos for AI or food analysis features;
voluntary attachments to workout sheets;
bug reports, screenshots, or images sent by the user;
explicit uploads of supported files or media.

3.6 Premium, AI Coach Credits, and Purchase Data

When you use Premium features or buy AI Coach credits, Holymp may process the data needed to manage access to the service and purchases, including:

the account’s Premium status;
AI Coach credit balance;
credits purchased (converted into points), points used, and remaining;
technical purchase data, such as store/platform, product id, transaction id, purchase token or receipt, technical identifiers, and related technical representations or hashes when used for verification and security.

Since the move to AI Coach points: balance of the points included in Premium (which renew every month) and of purchased points (which do not expire), with the movement log (date, action, points). The points log does not contain the text of your questions.

Holymp does not store full card details or full payment method details. Payment is handled by the store or payment provider shown in the purchase flow.

3.7 Technical, Security, and Log Data

Internal User ID.
Operation timestamps, session state, minimum diagnostics, and rate limit data.
Technical events necessary for security, abuse prevention, and service continuity.
For AI features, for every call to the provider, technical data (feature, model, token count, estimated cost, outcome, duration) without the text of the question or answer.

Some of the data above, including weight, wellness status, declared injuries, workout data, nutrition data, and Health Connect data, may qualify as health-related data.

4) App Permissions and Device Access

Depending on the features used, the app may request:

Camera.
Access to images, media, or files selected by the user.
Notifications.
Local notification scheduling, such as recovery timers.
Foreground service for an active timer.
Health Connect permissions to read steps, sleep, exercise/workout, and distance.
Optional, separate Health Connect permissions for resting heart rate and heart rate variability, requested only when turning on “Recovery signals”.

Permissions are requested by the operating system and can be revoked at any time from device settings. For Health Connect, revocation can also be managed from Android Health Connect settings.

5) Purposes and Legal Bases

Data is processed for:

Account creation, login, password recovery, profile management, provision of requested features, workouts, meals, synchronization, and premium.
Legal basis: Article 6(1)(b) GDPR.
Fitness/wellness summaries, activity analysis, personalized suggestions, and improvement of the user experience, including through Health Connect data when the user grants permissions.
Legal basis: Article 6(1)(b) GDPR for provision of the requested features and, where necessary, Article 9(2)(a) GDPR for health-related data based on explicit consent.
Management of purchases, subscriptions, AI Coach credits, and Premium features, including delivery of the purchased credit or feature, purchase status verification, support for payment or access issues, security, and prevention of fraud, abuse, or unauthorized reuse of receipts or tokens.
Legal basis: Article 6(1)(b) GDPR for performance of the service or purchase; Article 6(1)(c) GDPR for accounting, tax, or legal obligations; Article 6(1)(f) GDPR for security and fraud or abuse prevention.
Service security, abuse/fraud prevention, rate limiting, and technical incident management.
Legal basis: Article 6(1)(f) GDPR.
Legal, tax, and competent authority requirements.
Legal basis: Article 6(1)(c) GDPR.
Verification of the minimum age required to use the service in Italy, prevention of under-threshold use, and application of technical blocks required by applicable rules.
Legal basis: Article 6(1)(c) GDPR and Article 6(1)(f) GDPR.
Delivery of the AI Coach Chat (processing of questions, history, memory, confirmation of actions).
Legal basis: Article 6(1)(b) GDPR.
Delivery of AI Coach Nutrition (questionnaire, meal plan), also based on the health information you choose to provide.
Legal basis: Article 6(1)(b) GDPR and, for health-related data, explicit consent, Article 9(2)(a) GDPR, optional and revocable.
Chat answers based on your health and wellbeing data (Premium, adult users only).
Legal basis: explicit consent, Article 9(2)(a) GDPR (and Article 6(1)(a)), optional and revocable.
Review, by the authorised team, of the feedback you have authorised, to find mistakes and improve the features.
Legal basis: consent, Article 6(1)(a) and, if the text contains health data, Article 9(2)(a) GDPR; optional and revocable.
Technical logging of AI calls and control of costs and abuse.
Legal basis: Article 6(1)(f) GDPR (legitimate interest), with limited retention.

6) Nature of Provision

Data necessary for the account and main features is required to use the service.
Optional data, such as notes, attachments, some preferences, optional AI features, photos/files, and Health Connect integrations, is provided freely.
Failure to provide required data may prevent full or partial use of the app.
Failure to grant or revocation of Health Connect permissions does not prevent general app use, but may limit features, summaries, or suggestions based on that data.
Personalised Chat answers are reserved for adult users.
Using the Chat with personalised data and authorising review of feedback are optional: if you do not, the Chat remains usable for general questions and app help, and the thumbs only record rating and reason.
The health information in the AI Coach Nutrition questionnaire is optional: you can skip the health questions.

7) Third-Party Services and Data Recipients

Data may be processed by external providers appointed, where required, as processors.

Federated authentication: Google, if the user uses Google Sign-In.
Health Connect: Android platform used by the user to authorize reading of supported health/fitness data.
AI for the AI Coach Chat: Anthropic (Claude), United States, as data processor. It does not receive your name, email, password or tokens.
AI for the AI Coach (programmes and Nutrition), meal photo analysis and food classification: OpenAI, United States, as data processor. For AI Coach Nutrition it receives only constraints derived in code form; it does not receive your name or email.
Food estimation from text: DeepSeek (DeepSeek AI, China), a provider that processes the free text of the food you type to estimate its nutritional values. It does not receive your name, email, identifiers, profile data, workouts, weight or Chat data.
External food database, when used: OpenFoodFacts.
Technical emails, such as password reset: SMTP provider configured by the Controller.
Technical infrastructure: backend hosting, database, storage, network/CDN of the service.
Payment store: Google Play/Apple, depending on platform, for in-app purchase management.

Holymp does not sell personal data to third parties and does not use third-party behavioral advertising in the app.

8) Transfers Outside the EEA

Some providers may process data outside the EU/EEA. In such cases, the Controller adopts the safeguards required by Articles 44 et seq. GDPR.

Anthropic (for the Chat) and OpenAI (for the AI Coach, meal photos and food classification) are based in the United States.

For food estimation from text, the free text may be sent to a provider based in China, a country without a European Commission adequacy decision. The text sent does not contain any identifiers of yours. You can avoid this by choosing a food from the archive or by barcode.

9) Retention Periods

Data is stored for the time necessary for the purposes listed above.

Account/profile data: until account deletion, unless legal obligations apply.
Workout/nutrition/weight/attachment data and Health Connect data imported or used by the app: until deletion by the user or account deletion.
Password reset, OTP, or temporary token data: limited technical retention according to security configuration.
Purchase, Premium, and AI Coach credit data: stored only for as long as necessary to provide the purchased service, handle support, technical checks, security and fraud or abuse prevention, and comply with accounting, tax, or legal obligations.
Technical and security logs: kept for the time necessary for security, abuse prevention and service continuity.
Backups: limited rolling retention: 30 days.
Conversations and Coach memory: at most 12 months after last use, or until you delete them.
Copy of a feedback you authorised: at most 180 days; after that only aggregated anonymous statistics remain (for example how many ratings per reason and category), without text and without any link to your account.
AI Coach Nutrition health data: at most 12 months without use, or 30 days after Premium ends.
Support tickets: at most 24 months after closing.
Technical error reports: at most 90 days, with the email removed after 30 days.
If you delete a conversation after sending an authorised feedback, the copy may stay separate and without identifiers for up to 180 days; when you delete the conversation you can choose to delete the copy too.

When we receive a valid account deletion request, we delete the associated data except data that must be retained due to legal obligations or defense of rights.

10) Account Deletion

Account deletion is available in-app at:

Settings > General > Account > Delete account

The external channel required by app stores is also available:

External account deletion page URL: https://holymp.app/account-deletion/
Account deletion page in Italian: https://holymp.app/account-deletion/it
Account deletion page in English: https://holymp.app/account-deletion/en

Deletion immediately removes active content and any residual identifying link: conversations, memory, ratings and feedback copies still linked to the account, the points log and linked consents, except what we must keep for legal obligations or to defend rights. Feedback copies already separated from the account (because you deleted the conversation first) stay for at most 180 days, without any link to your account.

11) Security

Technical and organizational measures proportionate to the risk are adopted, including:

Encrypted connections in transit, HTTPS/TLS.
Authentication and authorization controls.
Data minimization.
Logical separation of access and protection of environments.
Account deletion and user content management procedures.

No system is completely invulnerable; measures are updated over time.

12) Data Subject Rights

Under the GDPR you may exercise:

access;
rectification;
erasure;
restriction;
objection, where applicable;
portability, where applicable;
withdrawal of consent, without affecting the lawfulness of previous processing.

For the AI Coach Chat you can also at any time: delete single conversations or the whole history, delete the Coach memory, and withdraw consent to personalised data and the authorisation for feedback from the Coach privacy screen. Withdrawal does not affect the lawfulness of previous processing.

To exercise your rights, write to: privacy@holymp.app.

You also have the right to lodge a complaint with the Italian Data Protection Authority.

13) Minors

For the current release in Italy, Holymp applies a minimum use threshold of 14 years.

During registration or first access, the full date of birth is requested.
If the minimum threshold is not met, access is technically blocked and the user cannot use the app features.
Any privacy consent given does not replace the minimum age requirement.
Personalised answers of the AI Coach Chat, which read app data, are reserved for adult users: between 14 and 17 the Chat only answers general questions and questions about using the app. AI Coach Nutrition is also reserved for adult users.

If we detect under-threshold use or data provided in violation of the limit, we adopt blocking measures and proceed, where requested and within technical/legal limits, with data deletion.

14) Automated Processes and AI Features

The app may generate automatic suggestions, such as nutritional estimates and workout optimizations.
These outputs are for informational support and do not replace professional medical, healthcare, nutrition, or personal training assessments.

The AI Coach Chat uses generative artificial intelligence models and can make mistakes. It does not make decisions that produce legal or similarly significant effects on you: it proposes, and actions on the app happen only after your confirmation. A cautious filter stops answers about pain and symptoms and asks you to see a professional.

15) Future Evolution of AI Features

In the future, Holymp may introduce additional processing to improve AI suggestion quality.
Before enabling new processing that is not compatible with this policy, the policy will be updated and, where necessary, dedicated consent will be requested.

16) Changes to This Policy

This policy may be updated over time.
The updated version will be published at the same URL or on the dedicated language pages and, where necessary, notified in-app.

17) Terms of Use and Disclaimer

https://holymp.app/terms/