REPSII PRIVACY POLICY
Snazzi Link FZCO, licence number 47958, registered at Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates, trading as “Repsii” (“Repsii”, “we”, “us” or “our”), respects your privacy and is committed to protecting personal data.
This Privacy Policy explains how we collect, use, disclose, store and protect information when you use the Repsii mobile applications, websites and related services (collectively, the “Services”). It applies to Customers and Trainers worldwide, subject to local data-protection laws.
For privacy questions or rights requests, contact admin@repsii.com.
1. Information We Collect
1.1 Account and profile information
We may collect information you provide, including your name, email address, account credentials, profile information and other information needed to create and manage your account.
1.2 Fitness and progress information
For Customers, we may collect fitness-related information you choose to provide or generate through the Services, including age, height, weight, measurements, workout preferences, workouts and workout results, calorie and macronutrient information, progress photographs and videos, and related progress information.
Repsii does not currently ask Customers to provide medical conditions, injuries, pregnancy information, medications or other medical-history information as part of the standard service.
1.3 Messages and communications
We process messages and other communications exchanged between Customers and their Trainers through Repsii, as well as support requests, complaints and feedback sent to Repsii.
1.4 Trainer information and content
For Trainers, we may collect profile and professional information, account information, Customer-management information, and training or coaching content uploaded or created for use through Repsii.
1.5 Device, usage and technical information
We may automatically collect device type, operating system, app version, device identifiers, IP address, approximate location, session and feature usage, analytics information, and crash, security or performance logs.
1.6 Payments and purchases
Purchases and subscriptions may be processed through Apple App Store, Google Play, Stripe or other authorised payment providers. Repsii does not ordinarily receive or store full payment-card details. We may receive limited transaction information such as subscription status, purchase confirmations, transaction identifiers and product information to manage access, payments, fraud prevention and support.
2. Apple Health / HealthKit
If you choose to connect Repsii to Apple Health, Repsii may request permission to read step data from HealthKit for fitness and progress functionality.
HealthKit access is optional. Apple provides controls through which you can grant, limit or revoke permissions. Repsii will request permission for each HealthKit data type it seeks to access.
If Repsii introduces additional HealthKit data types in the future, it will request the relevant permissions before accessing them and update its disclosures where appropriate.
Information obtained through HealthKit will not be used for advertising or similar marketing services, will not be sold to advertising platforms, data brokers or information resellers, and will not be disclosed to a third party except as permitted by applicable law, Apple’s requirements and the permissions you provide. Where a Customer has enabled Trainer access as part of the fitness service, relevant HealthKit information may be made available to that Customer’s Trainer for the purpose of providing fitness services.
3. How We Use Personal Data
Depending on the circumstances and applicable law, we may use personal data to:
create, authenticate and manage accounts;
provide, operate, personalise, secure and maintain the Services;
connect Customers with their selected Trainers and enable Trainers to provide coaching through Repsii;
display and process workouts, progress information, nutrition information, messages and other Customer features;
manage subscriptions, purchases, payments and access;
provide customer support and respond to complaints or requests;
send essential account, Trainer, payment, security, legal and service communications;
send direct marketing where permitted by applicable law and subject to applicable opt-out rights;
analyse and improve functionality, reliability and user experience;
detect, investigate and prevent fraud, abuse, security incidents, account sharing and violations of our Terms; and
comply with legal obligations and establish, exercise or defend legal claims.
4. Trainer Access to Customer Information
A Customer’s selected Trainer may access information made available through the Services for the purpose of providing coaching, including progress photographs and videos, weight and measurements, workouts and workout results, calorie and macronutrient information, permitted Apple Health information, and messages.
Progress photographs are intended to be viewable by the Trainer within Repsii. Repsii’s Terms prohibit Trainers from downloading, copying, screenshotting, publishing, distributing or otherwise misusing Customer progress photographs except where separately authorised or expressly enabled.
If a Customer stops subscribing to a Trainer, that Trainer may retain access to historic client records within Repsii where Repsii makes those records available. Repsii will handle such retention and access subject to applicable data-protection law, legitimate business needs, legal obligations, dispute requirements and this Policy.
5. Customer Content and Marketing Use
Customers retain ownership of their photographs, videos, messages and other Customer-created content. Repsii processes that content as necessary to provide, secure, support and administer the Services.
Repsii will not use Customer progress photographs or videos for advertising, social media, endorsements or promotional marketing without obtaining separate permission from the Customer.
6. Legal Bases for Processing
Where UK GDPR, EU GDPR or similar laws require us to identify a legal basis, the basis will depend on the information and purpose. We may rely on:
Contract – where processing is necessary to provide Services requested by you or take steps at your request before entering a contract;
Consent – where the law requires consent or you have chosen to grant permission, including certain marketing or device/health-data permissions;
Legitimate interests – where appropriate for operating and improving the Services, security, fraud prevention, support, enforcing our Terms and other legitimate business purposes, balanced against your rights;
Legal obligation – where processing is necessary to comply with law; and
Establishment, exercise or defence of legal claims or another applicable condition where sensitive or special-category data is involved and the law requires an additional condition.
Some fitness information, progress information or information obtained through health integrations may be treated as health data or special-category/sensitive data under applicable law. Where an additional legal condition or explicit consent is required, Repsii will use an appropriate condition or seek the required permission.
7. Marketing and Service Communications
We may send essential or service-related communications, including account notices, Trainer messages, purchase confirmations, security notices, legal notices and important changes to the Services. These communications are part of operating the Services and may continue while your account or relevant transaction remains active.
Where permitted by applicable law, we may send promotional communications about Repsii products, services or updates. Where applicable law gives you the right to opt out or object to direct marketing, you may exercise that right using the unsubscribe method provided or by contacting admin@repsii.com. Opting out of promotional marketing does not prevent essential service communications.
We may retain limited suppression information after an opt-out where necessary to ensure we continue to respect the marketing preference.
8. Sharing and Disclosure
We may disclose personal data to:
the Customer’s selected Trainer, as described in this Policy;
service providers supporting hosting, infrastructure, analytics, security, email delivery, customer support and other operational functions;
Apple App Store, Google Play, Stripe and other payment or platform providers as necessary for purchases, subscriptions and account functionality;
professional advisers, insurers, auditors or authorities where reasonably necessary and lawful;
law-enforcement, regulators, courts or other parties where required by law or necessary to protect rights, safety or security; and
a buyer, investor, lender or successor in connection with a merger, acquisition, financing, restructuring, insolvency or sale of all or part of the business, subject to appropriate safeguards.
Service providers may process personal data only for authorised purposes and are required to protect it appropriately. We do not sell HealthKit information to advertising platforms, data brokers or information resellers.
9. Analytics and Advertising
We may use analytics tools to understand use of the Services, diagnose problems and improve performance and functionality.
The Services do not currently display third-party advertisements. HealthKit information will not be used for advertising or similar services.
10. International Data Transfers
Because Repsii operates worldwide and is operated from the United Arab Emirates, personal data may be processed or stored in countries other than the country where you live.
Where applicable data-protection law restricts international transfers, Repsii will use an appropriate lawful transfer mechanism or safeguard, such as an adequacy mechanism, approved contractual safeguards or another permitted method.
11. Data Retention
We retain personal data for as long as reasonably necessary for the purposes described in this Policy, including providing the Services, maintaining legitimate business records, supporting Trainer-client records, complying with legal, tax and accounting obligations, preventing fraud, resolving disputes and enforcing agreements.
Retention periods may vary by category of data, the status of the account, the Trainer-client relationship and applicable law. When information is no longer required, we will delete, anonymise or otherwise securely dispose of it where appropriate.
Account deletion does not necessarily result in immediate deletion of every record, and deleting a Repsii account does not itself cancel a subscription administered by a payment provider.
12. Your Privacy Rights
Depending on where you live, you may have rights to access, correct, delete, restrict or object to processing of personal data, request portability, withdraw consent, opt out of certain marketing, or complain to a competent data-protection authority.
These rights are not absolute and may be subject to legal exceptions. To exercise a privacy right, contact admin@repsii.com. We may need to verify your identity before acting on a request.
Withdrawing consent does not affect processing that was lawful before withdrawal and does not necessarily require deletion where Repsii has another lawful basis or retention obligation.
13. Children and Teen Users
The Services are not intended for children under 13 and Repsii does not knowingly permit under-13s to create standard accounts.
Users aged 13 to 17 are required by the Repsii Terms to have permission from a parent or legal guardian. Repsii does not ordinarily verify that permission. Age and parental-consent requirements differ between countries, and Repsii may apply additional age, consent or verification measures where required by applicable law.
If we learn that personal data has been collected from a child in circumstances where collection was not legally permitted, we will take appropriate steps, which may include deletion or restriction.
14. Security
We use reasonable technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, loss or misuse. No system can be guaranteed completely secure.
Users are responsible for keeping account credentials confidential and should promptly notify Repsii of suspected unauthorised access.
15. Account Deletion
Account deletion may be available through the Repsii application or by contacting Repsii where applicable. Deletion requests are handled in accordance with applicable law and the retention principles above.
Account deletion is separate from subscription cancellation. If a subscription is administered through Apple App Store, Google Play, Stripe or another provider, you may need to cancel it separately using the applicable cancellation process.
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to the Services, our practices, technology or applicable requirements. We will post the updated Policy through the Services or our website and revise the “Last updated” date. Where required by law, we will provide additional notice or obtain consent for material changes.
17. Contact Us
Privacy questions, requests and complaints may be sent to:
Snazzi Link FZCO (trading as Repsii)
Licence no. 47958
Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates
Email: admin@repsii.com
Depending on your location, you may also have the right to complain to the data-protection regulator or supervisory authority responsible for your jurisdiction.