Privacy Policy

1. Summary

We collect information to provide personalized coaching and improve the Services. We:

• collect only what is reasonably necessary,
• use de-identified and/or aggregated data when feasible for analytics,
• use reasonable and appropriate safeguards designed to protect information, and
• give you controls over what you share (including integrations like Apple Health).

2. Data Minimization (HIPAA-Adjacent Practice)

We aim to collect and process only information reasonably necessary to provide the Services and the features you use.

You can limit what you share and disconnect third-party integrations at any time.

3. Information We Collect

Information you provide

• Name and email
• Account credentials
• Goals and preferences
• Training, nutrition, and sleep inputs and preferences
• Body composition inputs as goals and check-ins (e.g., weight, body fat %, muscle), if you choose to enter them
• Messages and transcribed voice with the AI Coach or human coaches
• Appointment-related details

Health and fitness information (optional)

If you connect Apple Health or provide data manually, we may collect the data types you authorize, such as:

• Activity and workouts
• Steps
• Sleep and heart rate (if authorized)
• Energy expenditure (if authorized)
• Body measurements and composition (if authorized or entered)
• Blood glucose data and other analytes (as shared by sensors to Apple Health only)
• Environmental data such as UV light exposure
• Location for sunrise/sunset times

Payment information

Payments are processed by third parties. We do not store full payment card numbers. We may store transaction records and receipts.

Automatically collected information

• Device identifiers and settings
• IP address and approximate location (derived from IP)
• App interactions and usage metrics
• Crash logs and performance diagnostics

4. How We Use Information

We use information to:

• Provide and personalize coaching and recommendations
• Adjust your plan over time
• Support paid coaching appointments
• Communicate about your account and service updates
• Improve our features and coaching effectiveness
• Protect against fraud, abuse, and security threats
• Comply with law

5. De-Identification and Analytics (Core Commitment)

When we analyze data to improve coaching and user experience, we use de-identified and/or aggregated data when reasonably feasible.

We remove or transform identifiers where appropriate and restrict access to those who need it.

De-identified/aggregated data may be used to:

• Improve personalization,
• Evaluate coaching effectiveness,
• Develop and test new features, and
• Improve the Services for all users.

De-identification reduces risk but does not eliminate it. We take reasonable steps to prevent re-identification.

6. Sensitive Information (HIPAA-Adjacent Practice)

Some information may be sensitive (for example, health and fitness metrics). We apply heightened protections such as restricted access, vendor controls, and secure storage practices.

7. How We Share Information

We share information only as needed to operate the Services:

Service providers

We use vendors for hosting, analytics, customer support, payments, and appointment scheduling. They are required by contract to protect information and use it only for authorized purposes.

Coaches

If you book a human coach appointment or request coach support, we share relevant information to provide the service.

Legal and safety

We may share information to comply with law or protect the rights, property, and safety of GOLD, our users, or others.

Business transfers

Information may be transferred in connection with a merger, acquisition, financing, or sale of assets, subject to protections.

No sale for money

We do not sell your personal information for monetary consideration.

8. Apple Health and Other Integrations

If you connect Apple Health:

• We access only the data types you authorize,
• You can revoke access in iOS settings at any time, and
• Apple's handling of your data is governed by Apple's policies.

9. Security

We use reasonable and appropriate administrative, technical, and physical safeguards designed to protect information. These may include:

• Encryption in transit and at rest where appropriate,
• Access controls and least-privilege policies,
• Monitoring and incident response procedures, and
• Vendor security diligence and contractual protections.

No system is completely secure. You are responsible for protecting your credentials and device.

10. Retention

We retain information as long as reasonably necessary to provide the Services, meet legal obligations, resolve disputes, and enforce agreements. We may retain de-identified/aggregated data longer for legitimate purposes.

11. Your Choices and Rights

Depending on your location, you may have rights to:

• Access, correct, delete, or export your information,
• Object to or restrict certain processing, and
• Withdraw consent where applicable.

To request these rights: privacy@gold.com

12. HIPAA Notice

Even when HIPAA does not apply, we aim to apply privacy and security practices aligned with high standards for sensitive information.

13. AI Transparency and Improvement

We may use de-identified and/or aggregated information to improve coaching quality, personalization, and safety. We may analyze user interactions (including messages) to improve the Services in a privacy-protective manner consistent with this policy.

14. Children's Privacy

The Services are not intended for children under 13 (or higher where required). If we learn we collected data unlawfully from a child, we will delete it.

15. International Users

If you use the Services outside the United States, your information may be transferred and processed in the U.S. or other countries where we and our vendors operate.

16. Changes to This Policy

We may update this Privacy Policy. If changes are material, we will provide notice. Continued use means you accept the updated policy.

17. Contact

GOLD, Inc.

9191 Towne Center Drive, Ste 150
San Diego, CA 92122

Contact Us

Legal representation: Cooley