Privacy Policy

1. Who Controls Your Information

AVERAGE PEOPLE LTD, company number 13576309, with its registered office at 128 City Road, London, United Kingdom, EC1V 2NX, operates TrainedBy and is the data controller for account, platform, security, support and service-administration data described in this policy.

Your coach may also be an independent data controller for coaching records they decide to collect and use in delivering their services. Where TrainedBy handles that information only on a coach's documented instructions, AVERAGE PEOPLE LTD acts as the coach's data processor. Contact your coach about their own coaching decisions and contact us about the TrainedBy platform or your TrainedBy account.

2. Information We Collect

We collect information you provide directly: account details (name, email, phone number where provided), fitness profile (height, weight, age, gender, training experience, goals), body-composition photographs (front, side and back views), meal and progress photos, form-check videos, voice notes, manual measurements, workout and nutrition data, check-ins, referrals, support requests and communications with your coach.

With your permission, the mobile app may read selected Apple Health or Google Health Connect data such as steps, weight, sleep, heart rate, heart rate variability, distance, workouts and workout routes where available so your coach can track progress and recovery. We also collect app diagnostics such as crash logs, device information, app version, and push notification tokens to keep the Service reliable and to deliver notifications you request or expect from your coach. We record the versions and time when applicable Terms and this Privacy Policy are accepted, including prior consent confirmed by your coach for an existing account.

3. How We Use Your Information

We use your information to provide requested coaching features, generate meal and body-composition analysis, facilitate communication between you and your coach, track fitness progress, sync authorised health information, send coaching and account notifications, protect account security, investigate crashes or support requests, process payments where applicable, comply with law and maintain reliable operation of the Service.

4. Lawful Bases and Health Data

We process personal data where it is necessary for the performance of a contract with you, where it is necessary for our legitimate interests in operating, securing, supporting and improving the Service and those interests do not override your rights, where we must comply with legal obligations, or where you have given consent. We use explicit consent where UK or EU data-protection law requires it for health, biometric or other special-category data, including optional Apple Health and Google Health Connect access.

You can withdraw your consent at any time in the applicable device or account settings or by contacting us. Withdrawal does not affect processing that was lawful before withdrawal, but the relevant optional feature may no longer work. Where we rely on legitimate interests, you may object as described below.

5. Google Gemini and AI Analysis

When you use an AI-assisted feature, TrainedBy may send the information required for that request to Google Gemini. This includes meal photographs for nutrition analysis and body-scan photographs and relevant profile details for requested body-composition analysis. Google processes that information as a service provider to return the requested result.

AI results are estimates and may be inaccurate.

Where you have agreed to this, TrainedBy may also use your body-scan and progress photographs, together with your measurements, scale readings and relevant profile details, to build and improve TrainedBy’s own body-composition and fitness models. The purpose is to make these estimates more accurate, both for you and for other clients. We never sell these photographs and we never use them for advertising or marketing profiling.

You can withdraw this permission at any time by emailing support@trainedby.fit. Withdrawal stops any further use of your photographs for this purpose. It cannot undo analysis or model improvement that has already taken place, because completed training cannot be separated back out.

Photographs used for this purpose are kept under the retention periods set out in section 7 (Data Retention) and are deleted on that schedule, or sooner if you delete your account.

6. Call Recording, Transcription and Coaching Notes

Coaches on eligible plans may use TrainedBy Call Notes, an identified meeting participant, to join scheduled online coaching calls. When Call Notes is enabled, it records the call audio, creates a transcript using contracted service providers including Google Gemini, and stores the recording and transcript as private coaching records. The transcript is available to the client's current coach and may be used through the coach's authorised Connected AI tools.

For a new client, accepting the current Terms and Conditions and Privacy Policy during onboarding records permission for Call Notes. For an existing client, the feature remains off unless the coach records the client's affirmative agreement. The identified bot is visible in the meeting and the meeting host may refuse or remove it.

A client may withdraw permission at any time through Settings → Privacy or by contacting TrainedBy. Withdrawal stops future capture and schedules deletion of retained call recordings and transcripts. Audio recordings are normally kept for no longer than 30 days and transcripts for no longer than 365 days, unless deleted earlier following withdrawal or retained only where required by law.

7. Data Retention

We retain account and coaching data while your account is active. After an authenticated deletion request, a seven-day grace period applies and deletion is completed within 30 days, subject to the limited exceptions below. Security, fraud-prevention, support and diagnostic records are kept only for as long as reasonably necessary for those purposes and any provider retention schedule. Backup copies are removed through their normal protected rotation and are isolated from ordinary use while awaiting deletion.

We retain company accounting and relevant payment records for six years from the end of the relevant financial year, or longer if applicable law, an investigation or legal proceedings require it. Records retained for legal compliance are access-restricted and are not used for unrelated product or marketing purposes.

8. Data Security

We implement industry-standard security measures to protect your data, including encryption in transit and at rest, access controls, and regular security audits. Body scan photographs can be stored in privacy mode, which limits access to AI analysis results only.

9. Your Rights

Depending on your location, you may have rights to access, correct, export, restrict, object to processing, withdraw consent or delete personal data. You can initiate account deletion in the TrainedBy mobile app or on our account deletion page. Google Play users may also review the public data-deletion instructions. You may complain to the UK Information Commissioner's Office or your local supervisory authority. For other requests, contact support@trainedby.fit.

10. Third-Party Services

We use third-party services for authentication, hosting, storage, push notifications, crash reporting, payment processing, and AI analysis. These include Firebase services, payment processors, Apple Health or Google Health Connect when you grant permission, and Google Gemini for requested AI analysis. We disclose only the information reasonably necessary for each provider to perform its contracted function and require it to be handled consistently with applicable data-protection obligations.

11. Connected AI Services

A coach may connect a supported external AI service to their own TrainedBy coach account. When the coach asks the connected service to use TrainedBy, it may receive only the TrainedBy records needed for that request and covered by the coach's permissions. This can include records or media belonging to clients the coach is authorised to manage, such as workout logs, meal logs, meal photographs, check-ins, measurements, coaching notes and authorised health or recovery records. Meal photographs may be provided when required for nutrition analysis. TrainedBy's Model Context Protocol (MCP) integration does not provide Connected AI with a client's body-scan or progress photographs; assessment results or measurements may be available without the underlying images. TrainedBy does not receive or collect the coach's unrelated AI conversations, raw prompts, or hidden model reasoning. TrainedBy does not initiate these disclosures on the coach's behalf. Plan-affecting proposals remain subject to review and approval inside TrainedBy, and the coach can revoke the connection.

12. Account Deletion

An authenticated deletion request creates a seven-day grace period and is completed within 30 days. You may cancel during the grace period. Completion removes or anonymises the client account and associated personal coaching data from active systems, subject to limited lawful retention described above, and removes access to the account. Account deletion is separate from cancellation or refund of coaching services and does not erase payment obligations for services or personalised content already supplied.

13. International Processing

Service providers may process information outside your country. Where required, we rely on an adequacy decision or use recognised transfer safeguards, including the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum, or the UK International Data Transfer Agreement, together with supplementary technical and organisational protections where appropriate.

14. Children's Privacy

TrainedBy is intended only for people aged 18 or older. We do not knowingly permit anyone under 18 to create or use a TrainedBy account. If you believe a person under 18 has provided personal data to TrainedBy, contact us so we can investigate and remove it.

15. Contact

The controller is AVERAGE PEOPLE LTD, company number 13576309, registered at 128 City Road, London, United Kingdom, EC1V 2NX. For privacy-related inquiries, contact us at support@trainedby.fit.