Privacy Policy

Effective Date: April 21, 2026

1. Our Core Privacy Commitment: Local-First Data Storage

WholeFiit is built on a local-first privacy model. All personal health and fitness data you enter into the App is stored directly on your device. We do not transmit, upload, or store your health data on external servers or in the cloud.

This means:

• Your fitness data, body measurements, calorie logs, workout history, and cycle tracking information never leave your device
• We cannot access, view, or retrieve your personal health data — it exists only on your phone
• If you delete the App or your device data, your health information is permanently removed
• You are in complete control of your data at all times

The only data transmitted to our systems is the minimum necessary to manage your account and subscription, as described below.

2. Information We Collect

2.1 Data Stored Locally on Your Device Only

The following data is collected and stored exclusively on your device and is never transmitted to Divine 360 LLC or any third party:

• Body measurements (weight, height, and custom measurements)
• Fitness and health data (workouts logged, calories consumed or burned)
• Cycle tracking data (menstrual cycle dates, symptoms, and related health notes)
• Workout history and progress logs
• Personal fitness goals and milestones

2.2 Data Transmitted to Our Systems

The following limited data is transmitted to and stored by Divine 360 LLC solely for account management and app functionality:

• Name and account credentials (email address, encrypted password)
• Subscription and billing status (processed securely through Apple App Store or Google Play — we do not store payment card details)
• Push notification tokens (to deliver reminders and alerts you have enabled)
• App usage analytics (aggregated, anonymized data such as features used, session duration, and crash reports — not linked to your health data)
• Device information (device type, operating system version, app version — for technical support and compatibility)
• Phone number (optional — provided during onboarding only if you choose to enable SMS workout reminders; transmitted to Twilio solely for SMS delivery)
• Referral data (your referral code, referral count, and credit balance stored in our database solely to operate the referral and rewards program)
• Merchandise fulfillment data (name, email address, and shipping address — collected only if you redeem a referral reward for physical merchandise; used solely to fulfill your order and deleted after shipment is confirmed)

2.3 Data We Do NOT Collect

We do not collect location/GPS data, camera or photo access, microphone data, contacts, or data from third-party health platforms such as Apple Health or Google Fit at this time.

2.4 AI Service Providers

WholeFiit uses artificial intelligence (Claude by Anthropic) to generate personalized workouts and meal plans. When you request AI-generated content:

• Your fitness goals, activity level, and health limitations (as provided by you) are transmitted to Anthropic's API solely to generate the requested content
• No personally identifiable information (name, email, address) is shared
• Data is not used by Anthropic to train their models
• Transmissions are encrypted in transit and not stored by Anthropic after processing

You may opt out of AI features by using manually selected workouts from the library instead of AI-generated sessions.

3. How We Use Your Information

We use the limited account and technical data we collect to:

• Create and manage your WholeFiit account
• Process and manage your subscription
• Send you push notifications about reminders, goals, and app updates (only if you grant permission)
• Send SMS workout reminder messages if you have opted in and are a Core or Pro subscriber
• Operate the referral and rewards program
• Fulfill merchandise orders when you redeem a physical reward
• Analyze aggregated, anonymized usage data to improve app performance and features
• Respond to customer support inquiries
• Comply with legal obligations

We never use your data for advertising, profiling, or sale to third parties.

Do Not Track Signals: Our systems do not respond to "Do Not Track" signals because we do not track users across third-party websites or services.

4. Health and Sensitive Data

Because all health and fitness data in WholeFiit is stored locally on your device, Divine 360 LLC does not have access to your personal health information. This is a foundational design decision made to protect your privacy.

In the event you contact our support team and voluntarily share health information to resolve an issue, that information is used solely to assist you and deleted after the matter is resolved.

5. How We Share Your Information

We do not sell or rent your personal information. We may share your limited account and technical data only in the following circumstances:

• California Residents (CCPA): WholeFiit does not sell your personal information. If you are a California resident, you have the right to request information about our data practices and to request deletion of your account data. Contact privacy@wholefiit.com to exercise these rights.
• Service Providers: Trusted third-party vendors who process data on our behalf under strict confidentiality agreements, including: Railway (cloud hosting and database), Twilio (SMS delivery — receives your phone number only if you enable SMS reminders), Printful (merchandise fulfillment — receives name, email, and shipping address only when you redeem a merch reward), and Stripe (payment processing — we do not store card details)
• Legal Requirements: If required by law, court order, or to protect the rights and safety of our users or the public
• Business Transfers: If Divine 360 LLC is involved in a merger, acquisition, or sale of assets, your data may be transferred. We will notify you before your data becomes subject to a different privacy policy

6. Push Notifications & SMS Reminders

WholeFiit may send you push notifications for workout reminders, goal milestones, and app updates. You can enable or disable push notifications at any time through your device system settings. We do not send marketing or promotional push notifications from third parties.

If you provide a phone number during onboarding, WholeFiit may send SMS workout reminder messages via Twilio if you have not logged a workout in 3 or more days (Core and Pro subscribers only). Standard message and data rates may apply. You can opt out at any time by texting STOP in reply to any message, or by removing your phone number in Settings. We do not share your phone number with any party other than Twilio for delivery purposes.

7. Data Retention

Account and subscription data is retained for as long as your account is active or as needed to provide the App services. If you delete your account, we will delete or anonymize your account data within 30 days, except for subscription transaction records required for tax purposes, which are retained for 7 years as required by law. Merchandise fulfillment data (shipping address) is deleted after shipment is confirmed. Because your health and fitness data is stored locally on your device, deleting the App removes that data entirely and immediately.

8. Your Rights and Choices

Depending on your location, you may have the following rights regarding your account data:

• Access: Request a copy of the account data we hold about you
• Correction: Request that we correct inaccurate or incomplete data
• Deletion: Request that we delete your account and associated data
• Portability: Request your account data in a portable format
• Opt-Out: Opt out of non-essential communications at any time

To exercise any of these rights, contact us at: privacy@wholefiit.com

Note: Because your health data is stored locally on your device, you have direct control over it at all times through your device settings and the App itself.

How to Delete Your Account:

You can delete your WholeFiit account at any time by:

1. Opening the WholeFiit app
2. Navigating to Settings → Account → Delete Account
3. Confirming your choice

When you delete your account:

• Your account credentials and subscription data are permanently removed from our systems within 30 days
• Your locally stored health data remains on your device. To remove it, delete the app or clear app data in your device settings.

Managing Your Subscription:

You can cancel your subscription at any time through:

• Apple App Store: Settings → Apple ID → Subscriptions
• Google Play: Play Store → Menu → Subscriptions

Cancellations take effect at the end of the current billing period. No refunds for partial periods.

9. Data Deletion Requests & Children's Privacy

WholeFiit is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have inadvertently collected such data, we will delete it promptly.

To request deletion of your account data from our systems:

• In-app: Settings → Account → Delete Account
• Email: privacy@wholefiit.com with "Delete My Account" in the subject line

We will confirm receipt within 48 hours and complete deletion within 30 days. Your locally stored health data can be deleted by uninstalling the app or clearing app data in your device settings.

10. Security

We implement industry-standard security measures for account and technical data transmitted to our systems, including encryption in transit (TLS), encrypted password storage, and access controls. Because health data is stored locally on your device, it is protected by your device's own security features including device encryption and biometric authentication.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the effective date and notify you via the App or email. Continued use of WholeFiit after changes are posted constitutes your acceptance of the revised policy.

12. Your GDPR Rights (For European Union Users)

If you are located in the European Union, you have the following rights under the General Data Protection Regulation (GDPR):

• Right to Access: Request a copy of your account data
• Right to Rectification: Correct inaccurate data
• Right to Erasure: Request deletion of your account
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a portable format
• Right to Object: Object to processing based on legitimate interests

To exercise these rights, contact privacy@wholefiit.com. We will respond within 30 days.

Legal Basis for Processing: We process your account data based on your consent (when you create an account) and our legitimate interest in providing the App services.

13. Contact Us

If you have questions or concerns about this Privacy Policy, please contact us:

WholeFiit Operated by Divine 360 LLC
Email: privacy@wholefiit.com
Website: www.wholefiit.com
Divine 360 LLC
c/o Sheniya Griffith
2248 Broadway #2152
New York, NY 10024
United States