1. Introduction and general provisions
1.1. This Camera and Live Video Processing Notice (the “Notice”) establishes the principles, purposes, technical arrangements and privacy safeguards governing access to and processing of live camera information in connection with the mobile application operating under the name Coach.ai (the “Application”), together with its associated software, artificial intelligence functionalities, exercise monitoring capabilities, instructional materials, digital content, updates and related services (collectively, the “Services”). The Application is developed, maintained and operated by Stay Fit Software - FZCO, a legal entity duly incorporated under the laws of United Arab Emirates (the “Company”, “we”, “us” or “our”).
For the purposes of this Notice, “User”, “you” and “your” refer to any natural person who downloads, installs, registers for, accesses or otherwise uses the Application.
1.2. The Application provides artificial intelligence-assisted fitness coaching, exercise monitoring, movement analysis and automated exercise guidance. Certain functionalities rely on computer vision and locally executed analytical technologies to interpret physical movements, assess selected elements of exercise technique, count repetitions and provide real-time feedback. To perform these functions, the Application requires temporary access to the camera incorporated into the User's device.
1.3. This Notice applies specifically to the Application's access to the device camera, the temporary processing of live video frames and movement information, the generation of exercise-related outputs and the associated privacy safeguards. It also explains the distinction between temporary visual processing and the optional retention of non-video exercise information as part of the User's saved workout history.
1.4. This Notice supplements the Company's Terms and Conditions of Use and End-User Licence Agreement and Privacy Policy. The Privacy Policy provides comprehensive information regarding the Company's processing of personal data, legal bases, retention arrangements, data recipients and statutory data protection rights. Nothing in this Notice excludes, restricts or replaces any consent, authorisation or disclosure required under applicable legislation.
2. Purpose and necessity of camera access
2.1. Camera access is used solely for the provision of camera-assisted exercise monitoring and related fitness coaching functionality. The Application analyses visual information obtained during an active workout to recognise supported movements and generate corresponding exercise-related feedback.
2.2. The Application may use live camera information to estimate body positioning, detect movement patterns, assess selected aspects of posture and identify certain deviations from recognised exercise movement patterns. Such analysis is intended to assist Users in understanding the execution of supported exercises.
2.3. Where supported, the Application may automatically count completed exercise repetitions, identify exercise phases and generate corresponding training observations. The resulting outputs may be displayed through visual indicators, textual instructions or other interfaces provided within the Application.
2.4. Camera access is necessary only for features that depend on visual movement analysis. Where a feature can operate independently of camera access, withdrawal or refusal of camera permission shall not, where technically feasible, prevent the User from accessing that unrelated functionality.
2.5. The Company does not use camera access for unrelated surveillance, advertising profiling, facial recognition, identity verification or monitoring of the User outside an active exercise session. The Application is not designed to activate the camera without the User initiating the relevant camera-assisted functionality.
3. Exclusively on-device video processing
3.1. All camera-based exercise analysis is performed exclusively within the computational environment of the User's device. The Application utilises locally executed software functionality and device processing resources to analyse live camera frames. No external server connection is required for the processing of the underlying camera footage.
3.2. The Company does not transmit, upload or otherwise transfer live camera footage, original video frames or video recordings from the User's device to Company-controlled servers. The underlying visual information is not transmitted to third-party artificial intelligence platforms, external computer vision services or remote video-analysis infrastructure.
3.3. The Company does not maintain remote access to Users' live camera feeds. Company personnel, administrators and support representatives are not provided with a functionality allowing them to remotely observe a User's active exercise session through the Application.
3.4. During an active training session, individual video frames and corresponding analytical information may temporarily exist in device memory for the purpose of executing the relevant movement analysis. Such temporary computational processing is necessary for the functionality of the Application and does not involve the creation of a persistent video recording.
3.5. When a User ends a camera-assisted training session, the Application ceases the relevant exercise video-analysis operations. Temporary processing information is discarded when no longer necessary for the relevant computational operation and is not maintained as historical workout footage.
4. No video recording, storage or retention
4.1. The Application does not create permanent recordings of the User's exercise sessions. Camera footage is processed in real time and is not saved as a video file for subsequent playback or review.
4.2. The Company does not maintain servers, databases or archives containing User workout videos collected through the Application. Video footage is not associated with registered User accounts as a persistent media record.
4.3. The Company does not provide a feature allowing Users or Company personnel to retrieve previously processed workout video footage. Since the Application does not create or maintain recordings of completed sessions, historical video footage is not available for subsequent access, export or disclosure.
4.4. Workout video footage is not included in the Company's account backups, workout history backups or other centrally maintained data archives.
4.5. The Company does not sell, license, distribute or otherwise commercially exploit camera footage obtained during exercise sessions.
4.6. The Company does not use camera footage for behavioural advertising, marketing profiling or the development of advertising audiences.
4.7. The Company does not collect, retain or transmit User workout footage for the training, fine-tuning or development of artificial intelligence models. The Application does not create centralised datasets of identifiable workout videos.
5. Categories of visual information processed
5.1. The Application temporarily accesses visual frames generated by the device camera during an active training session. Such frames may depict the User, clothing, exercise equipment and elements of the surrounding environment. The Application processes these frames for the limited purpose of extracting information relevant to supported exercise-monitoring functions.
5.2. The Application may derive temporary representations of body positioning, including estimated locations of joints, skeletal landmarks and relative positions of body segments. Such information supports the analysis of posture, exercise execution and movement patterns.
5.3. The Application may analyse movement trajectories, exercise phases, repetition patterns and other observable characteristics relevant to the performance of supported exercises.
5.4. For the purpose of providing automated feedback, the Application may generate intermediate computational information derived from visual inputs. Such representations are processed locally and are not independently retained as a permanent record of the User's physical characteristics unless they are transformed into an exercise-related metric that the User elects to save.
5.5. The Application is not intended to analyse facial identity, emotions, ethnicity, religious characteristics, personal relationships or other attributes unrelated to exercise execution. No functionality is intended to derive unrelated personal profiles from the User's camera footage.
6. Distinction between live video and saved workout history
6.1. The Application distinguishes between temporary video information required for real-time exercise analysis and exercise-related information that may be retained for future reference. The former is processed locally and discarded, while the latter may be saved through the User's registered account.
6.2. Where the User chooses to save workout information, the Application may retain exercise classifications, session dates, workout duration, repetition counts, performance indicators and automated movement assessments. Such information may be associated with the User's account for the purpose of maintaining training history and providing progress-monitoring functionality.
6.3. Saving workout history does not result in the storage of the original video frames or recordings used to generate exercise-related outputs. The Company does not maintain a technical association between saved workout records and retrievable historical video footage.
6.4. Saved workout information may be maintained within Company-controlled account infrastructure located in the European Economic Area. Such processing is separate from the locally executed video-analysis functionality and is governed by the Company's Privacy Policy.
6.5. Saved workout records shall ordinarily remain associated with the User's account until deleted by the User, removed pursuant to a valid erasure request or deleted upon permanent account deletion. Any exceptional retention shall be subject to the conditions and legal bases identified in the Privacy Policy.
7. Camera permissions and user control
7.1. The Application shall request access to the device camera through the permission mechanisms provided by the relevant operating system. Camera access shall be requested in connection with the relevant functionality and shall not be treated as an unrestricted authorisation for unrelated processing.
7.2. Before the initial activation of camera-assisted coaching, the Company shall provide clear information concerning the purpose of camera access, the exclusively on-device nature of visual processing and the absence of permanent video recording. The disclosure shall be made available in an accessible manner within the Application.
7.3. Camera-assisted exercise monitoring is initiated by an affirmative action of the User, such as selecting or starting a camera-supported training session. The Application does not intentionally activate the camera for exercise monitoring outside a session initiated by the User.
7.4. Users may revoke camera permission at any time through their device's operating-system settings. Users may also terminate the relevant camera-processing activity by ending the active workout session.
7.5. Where camera access is unavailable or withdrawn, functionalities dependent upon visual movement analysis may cease to operate. Other Services that do not require camera access may remain available, subject to the Application's technical design.
7.6. The Company shall not intentionally circumvent camera permissions or operating-system privacy controls to access visual information contrary to the User's choices.
7.7. An operating-system camera permission constitutes technical authorisation for the Application to access a device feature. It does not necessarily constitute consent under Article 6 or explicit consent under Article 9 GDPR. Where a separate legal consent mechanism is required for the relevant personal data processing, the Company shall implement that mechanism independently.
8. Artificial intelligence and automated analysis
8.1. The Application uses automated analytical systems to interpret visual movement information and generate exercise-related outputs. These systems operate without the continuous observation or supervision of a human personal trainer.
8.2. Automated analysis may be affected by device performance, camera positioning, lighting, visual obstructions, clothing, exercise complexity and the speed or characteristics of physical movement. The Company does not guarantee that all movements, exercise repetitions or posture irregularities will be identified accurately.
8.3. The Application is not intended to establish or authenticate the unique identity of an individual through facial recognition or other biometric identification systems. The generation of skeletal landmarks and movement representations is undertaken for fitness analysis rather than personal identification.
8.4. Certain exercise-related information may reveal aspects of an individual's physical health or condition. Where applicable, such information shall be treated in accordance with the relevant requirements of Articles 6 and 9 GDPR.
8.5. The Application does not use camera analysis to diagnose medical conditions, assess clinical health status or provide medical treatment. Exercise-related feedback is intended for general fitness and wellness purposes.
8.6. Users should exercise independent judgment when following automated recommendations. The Application shall not be relied upon as a substitute for professional medical assessment or qualified supervision where such assistance is appropriate.
9. Data protection and security safeguards
9.1. The Application incorporates a processing architecture designed to minimise the exposure of raw visual information. By performing video analysis locally, the Application avoids the central collection, transmission and permanent storage of workout footage.
9.2. Visual processing shall be limited to information reasonably necessary for the relevant exercise functionality. The Company shall not intentionally introduce unrelated camera-based processing without an appropriate legal assessment and disclosure.
9.3. The Company shall maintain appropriate technical and organisational safeguards consistent with the GDPR, taking into account the nature and risks of the processing. Such safeguards may include restricted application permissions, secure software development procedures, isolation of temporary computational information and controls designed to prevent unnecessary persistence of camera frames.
9.4. The Application does not integrate third-party analytics, advertising, behavioural tracking or external AI processing SDKs. No third-party SDK is authorised to independently collect workout camera footage through the Application.
9.5. Because camera footage remains on the User's device and is not uploaded to Company infrastructure, the Application does not transfer such footage outside the European Economic Area through its ordinary processing operations. The location and handling of centrally stored account information and saved workout history are separately addressed in the Privacy Policy.
9.6. Where a security incident involves personal data processed by the Company, the Company shall assess and fulfil its obligations under applicable data protection legislation. The local processing architecture does not eliminate the Company's responsibility to maintain appropriate security safeguards.
10. Data retention and deletion
10.1. Live camera footage is not persistently retained. Temporary visual information is discarded when no longer required for the corresponding analytical operation.
10.2. Intermediate movement-analysis information is processed for the duration necessary to produce relevant exercise-related outputs. Such information is not stored as a permanent record unless it forms part of a distinct non-video exercise metric expressly saved through the Application's workout history functionality.
10.3. Where the User saves exercise information, such records remain subject to the retention and deletion arrangements described in the Privacy Policy.
10.4. Users may request permanent deletion of their registered accounts through the Application or the designated account deletion webpage. The Company aims to complete deletion of personal data from active operational systems without undue delay and, under its ordinary procedure, within thirty (30) calendar days following receipt and verification of a valid deletion request.
10.5. Saved account and workout information contained in restricted system backups may remain temporarily under the Company's standard backup rotation arrangements, which shall not ordinarily exceed ninety (90) calendar days. These backup arrangements do not involve the retention of workout video recordings.
10.6. Where retention of particular non-video information is required or permitted by law, the Company may retain the relevant information for the legally justified period. Such retention shall not be used to create or maintain historical workout footage.
11. Third-party privacy and environmental considerations
11.1. Users are encouraged to conduct camera-assisted workouts in an environment that reasonably protects their privacy and the privacy of others.
11.2. The camera's field of view may incidentally include other individuals. Users should take reasonable measures to avoid unnecessary inclusion of third parties during a training session.
11.3. The Application is not designed to identify, authenticate or track third parties who may incidentally appear within the camera's field of view.
11.4. The camera may incidentally capture visual information concerning the User's surroundings. The Application does not intentionally analyse such information for advertising, surveillance or unrelated profiling purposes.
12. User rights and legal protections
12.1. Where camera-derived information or saved exercise records constitute personal data, Users benefit from applicable rights under the GDPR. Such rights may include access, rectification, erasure, restriction, portability, objection and withdrawal of consent, subject to the conditions established by law.
12.2. The Company does not maintain copies of live camera footage processed locally on Users' devices. Accordingly, the Company cannot provide historical video recordings that it has not collected or retained. This does not diminish rights concerning personal data actually held by the Company.
12.3. Users may exercise their rights concerning saved exercise records through the mechanisms provided by the Application or by contacting the Company.
12.4. Where processing relies on consent, Users may withdraw that consent at any time. Withdrawal shall not affect the lawfulness of processing performed before withdrawal.
12.5. Requests concerning personal data may be submitted to hello@coach.ai. The Company shall respond in accordance with the deadlines and procedures established by the GDPR.
12.6. Users have the right to lodge a complaint with a competent data protection supervisory authority. Where the Company is established in Lithuania, the relevant authority is generally the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija).
13. Apple App Store and Google Play Store
13.1. The Application requests camera access through the permission mechanisms provided by iOS and Android. Users remain able to manage the relevant device permissions through the operating system.
13.2. The Company shall provide an appropriate camera-processing disclosure before the initial use of camera-assisted coaching. Such disclosure shall explain the purpose of camera access and the locally executed, non-recording nature of the processing.
13.3. The Company shall maintain accurate App Store privacy disclosures reflecting the Application's camera processing architecture and the distinction between temporary local video analysis and saved exercise information.
13.4. The Company shall maintain accurate Google Play Data Safety disclosures and implement any additional prominent disclosure and consent mechanisms required under applicable Google Play User Data policies.
13.5. Apple and Google may separately process information in connection with their respective platform services in accordance with their own legal and privacy arrangements. Such independent processing does not alter the Company's commitment not to upload or retain workout camera footage through the Application.
14. Changes to camera processing practices
14.1. The Company may modify camera-related functionality where reasonably necessary for technical improvement, security, compatibility or compliance with applicable law.
14.2. Any proposed introduction of persistent video recording, cloud-based video analysis, external visual processing, biometric identification or materially different secondary uses of camera footage shall require prior assessment under applicable data protection legislation.
14.3. Where a material change affects the manner in which camera information is collected or processed, the Company shall provide appropriate notice before the relevant processing commences.
14.4. Where consent, explicit consent or additional device permissions are legally required, the Company shall obtain the relevant authorisation before activating the new processing functionality.
14.5. The Company shall update this Notice and any corresponding Privacy Policy or in-app disclosure to reflect material changes in processing practices.
15. Contact information
For questions concerning camera access, live video processing, movement analysis, privacy safeguards or statutory data protection rights, Users may contact: hello@coach.ai.
16. Final provisions
16.1. Camera information is processed exclusively for the purposes of providing supported exercise monitoring and automated fitness coaching functionality.
16.2. The Company maintains an exclusively on-device camera-analysis architecture under which raw video footage is not uploaded to remote infrastructure.
16.3. The Company does not record, archive or permanently retain video footage generated during the User's exercise sessions.
16.4. Where the User elects to save exercise-related information, such records are maintained separately from temporary video footage and remain subject to the Company's Privacy Policy.
16.5. Nothing in this Notice excludes, restricts or diminishes rights or protections granted under the GDPR or other applicable mandatory legislation.
16.6. This Notice enters into effect on the Effective Date indicated above and shall remain applicable until amended or replaced in accordance with its provisions and applicable law.