Last updated: 6 September 2026. Version 2026-09-06.
1. Controller
Grupo Efamaa, Colombian tax ID (NIT) [[NIT]], Cra. 7 #156-80, Torre 3 Oficina 1805, Bogotá, Colombia. For its Brazilian operation: CNPJ [[CNPJ]], registered at [[DOMICILIO_BR]]. For anything about personal data: [email protected].
Data protection officer. Article 41 of Brazil's LGPD requires a named contact for personal-data matters, and here is ours: [[DPO_NOMBRE]], [[DPO_CORREO]]. You can write to them directly, and also to your country’s data protection authority.
2. What we collect, and what for
Account data: first name, last name, email, country, language and, if you give it, phone number. Used to identify you, send your sign-in code and issue the invoice. Without these there is no account.
Questionnaire answers, each for its own purpose: goal, starting point, time available and the equipment you have at home are used to build your plan, and without them there is no plan. Age, to check you are of legal age. Time of day, to know when to send your email. Weight, to measure your progress: it is your first measurement. Sex, to choose who appears in the videos: if you are a woman, a woman performs the movements. The health screening answers, to decide whether we can give you a plan or have to send you to a doctor first. Height and food preferences are not used for anything today: you can leave them out.
Training activity: which sessions you do, which sets you complete, when, and how many reps you had left at the end of each movement, if you choose to tell us. Used so the plan progresses: it's what decides when you move up to a harder exercise. It's optional, and skipping it changes nothing else.
Measurements and progress photos, if you choose to give them. Genuinely optional: the plan works the same without them.
Technical data: IP address and browser, in the access logs, to detect abuse and protect your account.
3. Health data: special category
The screening answers, the medical flags, weight, height and progress photos are health data. The law gives them heightened protection: Article 9 of the GDPR, Article 11 of Brazil's LGPD and Article 6 of Colombia's Law 1581.
The legal basis for processing them is your explicit consent, given when you accept this policy at sign-up, and which you can withdraw at any time by deleting your account from Settings.
This data is not sold, not shared with advertisers and not used for advertising. There are no exceptions.
4. Who it is shared with
Nobody, other than the providers the service needs to run:
The email provider, to send your sign-in code and service emails. It receives your address and the message.
The hosting and storage provider, where the database lives and where your encrypted photos are stored.
The AI provider, which rewrites more warmly sentences our engine has already decided. It receives the text to rewrite, not your identity.
The payment provider, once enabled, which receives what it needs to charge you. We never see or store your card number.
And the authorities, if a court order requires it.
5. Where it lives and how long
Data is hosted on servers that may be outside your country. Where it leaves the European Economic Area or Brazil, the transfer relies on the relevant provider's standard contractual clauses.
Your account and its data are kept while the account exists. When you delete it they are erased, except what the law requires us to keep: invoices, for the tax retention period.
A questionnaire started and abandoned without an account deletes itself after thirty days.
6. Your rights
You can access your data, correct it, erase it, take it away in a file, object to processing, ask for restriction, and withdraw your consent.
You do not need to write to us for the essentials: from Settings you can export all your data and delete the whole account yourself, without asking anyone. For anything else, [email protected]; we answer within fifteen business days at the latest.
If you think we are getting this wrong, you can complain to your national data protection authority in the European Union, to the ICO in the United Kingdom, to the ANPD in Brazil, or to the Superintendencia de Industria y Comercio in Colombia.
7. How we protect it
Health answers and photos are stored encrypted. Photos are stripped of metadata—including GPS location—before being saved. We store no passwords, because there are none: you sign in with a single-use code that expires in ten minutes. Codes are stored one-way, never in the clear.
8. Children
The service is not aimed at minors and we do not knowingly collect their data. If we find an account belonging to a minor, we delete it.
9. Automated decisions
Your plan is calculated by a deterministic program from your answers: the same answers always give the same plan. There is no profiling with legal effects. You can change your answers whenever you like and the plan is rebuilt.
The health screening does have one automatic consequence: if you check a flag, no plan is generated and nothing is charged. You can ask for human review by writing to us.
10. Changes
If we change this policy we email you thirty days in advance.