Privacy Policy

Last updated: August 23, 2026

1. Who we are

Somatics, Incorporated (“Somatics”, “we”, “us”), a North Carolina corporation of 3925 Newhall Drive NW, Hickory, North Carolina 28601, United States, operates the Somatics Fitness & Nutrition mobile application (“SFN”, the “App”). We are the controller of the personal information described in this policy.

2. Scope

This policy covers the App and the services that support it. It does not cover our website, which is a separate set of static pages and has its own Website Privacy Policy, nor any third-party service you reach from the App. It should be read alongside our Terms of Service.

3. What we collect

Everything below is information you enter or generate by using the App. We collect no information about you from any other source, and we do not buy data about you.

3.1 Account information

3.2 Health and fitness information

This is the substance of the App, and most of it is sensitive information under one or more privacy laws. We treat it accordingly.

3.3 Consent records

When you accept our Terms, agree to marketing, or agree to receive text messages, we record when you did so and which version of the wording you agreed to. These are compliance records. We keep them for as long as we may need to evidence your consent, including after you delete your account.

3.4 Purchases

If you subscribe, our payments provider records your subscription status, plan, and renewal state. We never see or receive your card details. Payment is handled entirely by Apple.

3.5 Content you send us

Questions you type to the in-app assistant, and any photograph of a meal you choose to submit for recognition. Section 10 explains exactly what happens to each.

4. What never leaves your phone

Some of what the App shows you is never transmitted to us at all. It is held only in the App’s storage on your device, and it is destroyed when you delete the App or your account.

5. What we do not collect

• We do not track you across apps or websites. The App contains no advertising identifier collection, no cross-app tracking, and no third-party analytics or attribution software of any kind.
• We do not collect your location.
• We do not collect your contacts, photos library, calendar or microphone. A meal photograph is submitted only when you choose to submit one.
• We do not log the contents of your requests. Neither the App nor our servers write the body of a message or a photograph to any log.

6. How we use it

We use the information described above for the following purposes, which we may expand as the App develops:

• Operating the App: calculating your targets, storing your logs, and keeping your data available across your devices.
• Creating, securing and administering your account, and verifying your identity when you sign in.
• Providing the features you use, including the assistant, food and recipe search, and the plan and recipe builders.
• Personalising what the App shows you, including recommendations, suggested weights, and content we think is relevant.
• Developing, testing, debugging and improving the App and any future products or services we offer.
• Customer support, and responding to you when you contact us.
• Marketing and promoting our own products and services to you, where you have agreed to hear from us or where we are otherwise permitted to contact you.
• Measuring how the App is used in aggregate, so we can decide what to build.
• Detecting and preventing fraud, abuse and security incidents, and enforcing our Terms.
• Complying with law, and establishing, exercising or defending legal claims.

Where we introduce a new feature, we may use information we already hold to provide it, provided the new use is compatible with the purposes above or we have obtained your consent where one is required.

7. Legal bases

Where the GDPR or UK GDPR applies to you, we rely on the following:

8. Who we share it with

We share personal information with the service providers below, each of which processes it on our instructions and for no purpose of their own except as stated. We may add or change providers.

We may also disclose personal information:

• to our affiliates, and to professional advisers such as lawyers, auditors and insurers;
• in connection with a merger, acquisition, financing, reorganisation or sale of assets, in which case your information may be among the assets transferred, and the recipient may continue to use it as described here;
• where required by law, legal process, or a governmental request, or where we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

9. Apple Health

If you connect Apple Health, the App reads your step count, active energy and heart rate to display them on your dashboard.

• The App reads only. It writes nothing back to Apple Health.
• These readings stay on your device. They are never transmitted to us or to anyone else.
• We do not use Apple Health data for advertising or marketing, and we do not sell it, share it with brokers, or disclose it to third parties for their own purposes.
• You can revoke access at any time in the iOS Health app, and the App will simply stop showing those figures.

10. AI features

The assistant

When you send a message to the in-app assistant, the text of that message is sent to our server and passed to Google’s Gemini service, which generates the reply.

Nothing else about you goes with it. Not your profile, not your food log, not your weight, not your targets, not your name. The assistant does not know who you are, and its answers are general rather than personalised. Your conversation history is stored on your device and is not uploaded to us.

Meal photographs

If you photograph a meal for recognition, the image is resized on your device and forwarded to FatSecret to be identified. We do not store it. It is not written to a database, a log or a storage bucket by us at any point. FatSecret’s own handling is governed by their terms.

The builders

The plan and recipe builders send the instructions you type, together with the relevant parameters you have set in the App, to generate a result. The result is saved to your account as a plan or recipe like any other.

11. De-identified and aggregated data

We may create de-identified and aggregated information from the data we hold: statistics, trends, models and datasets that do not identify you and cannot reasonably be used to identify you.

We may use, retain, disclose, license and commercialise de-identified and aggregated information for any purpose, indefinitely, including after you delete your account. This includes research, publishing statistics about how people eat and train, improving our products, developing new ones, and training models. Where we do this, we will maintain the information in de-identified form and will not attempt to re-identify it, except as permitted by law to test our de-identification.

12. Advertising

Free accounts see advertising supplied by Google AdMob. Subscribers do not see advertising.

• We request non-personalised advertising only. Ads are selected on general context rather than on a profile built from your behaviour.
• We do not give advertisers your health data, food logs, workouts, weight, name, email or phone number.
• Google receives the technical information necessary to serve and measure an ad, which is described in its own policies.
• The App does not request permission to track you across other companies’ apps and websites, and does not do so.

13. Messages and email

We send a verification code by text message when you sign in. This is a service message, not marketing, and it is required to use the App.

Separately, and only if you agree, we may send you marketing by text message or email. Message frequency varies. Message and data rates may apply. You can stop text messages at any time by replying STOP, and get help by replying HELP. You can stop marketing email using the unsubscribe link in any message, or in the App’s settings.

We do not share your mobile number with third parties for their own marketing purposes.

14. Retention and deletion

We keep your information for as long as your account exists, and afterwards for as long as we need it for the purposes described in this policy or to meet a legal obligation.

Deleting your account

You can delete your account from within the App. When you do:

1. Your account is scheduled for deletion and you are signed out.
2. There is a 30-day grace period. Signing in during that window cancels the deletion and restores your account.
3. After 30 days your account and its data are permanently removed. This cannot be undone.

Deleting the App from your phone removes everything held on the device. It does not by itself delete your account.

We may retain consent records, transaction records, and information we need to comply with law, resolve disputes or enforce our agreements, after deletion. De-identified and aggregated information is not affected by deletion, as set out in section 11.

There is one further exception, and it concerns the referral program. If a mobile phone number is referred, we keep a one-way hash of that number, and we keep it after the account is deleted. We do this for a single purpose, which is to enforce the rule that a phone number can be referred only once. Storing the hash rather than the number means the record does not hold your phone number in readable form. We never use it to contact you, to advertise to you, or to restore a deleted account, and we do not collect or derive any device identifier for this or any other purpose. The program rules are in section 26 of our Terms of Service.

15. Your rights

Depending on where you live, you may have some or all of the following rights: to access the information we hold about you; to correct it; to delete it; to receive a portable copy; to object to or restrict certain processing; to withdraw a consent you have given; and to be free from discrimination for exercising any of them.

To exercise a right, contact us using the details in section 20. We will verify your identity before acting, and will respond within the period the applicable law requires.

16. Age requirement

SFN is for adults. You must be 18 or over to create an account. The App asks your date of birth during setup and will not create an account for anyone under 18.

We do not knowingly collect information from anyone under 18. If we learn that we have, we will delete it. If you believe a minor has given us information, contact us and we will remove it.

17. International transfers

We and our service providers operate in the United States, and your information will be stored and processed there. If you are outside the United States, using the App involves transferring your information to a country whose data protection laws may differ from your own. Where required, we use appropriate safeguards such as the European Commission’s standard contractual clauses.

18. Security

We take reasonable measures to protect your information, including transport encryption on every connection, storage of your session credentials in the iOS keychain, database access rules that restrict each account to its own records, and server-side verification of every request.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

19. Changes

We may update this policy. When we do, we will change the date at the top and post the new version. If a change is material, we will give you notice in the App or by email before it takes effect. Continuing to use the App after a change takes effect means you accept the updated policy.

The App records which version of our Terms and this policy you accepted, and when.

20. Contact

For any question about this policy, or to exercise a privacy right, contact us at somaticsfn@gmail.com, or write to Somatics, Incorporated, 3925 Newhall Drive NW, Hickory, North Carolina 28601, United States.

21. Consumer health data

This section covers consumer health data. It is here because Washington's My Health My Data Act, Nevada's Senate Bill 370, and similar laws in other states treat health information as a category of its own and require us to describe it separately. It adds to the rest of this policy rather than replacing it. Where anything in this section differs from another section, this section governs for consumer health data.

We are not a healthcare provider. We are not a covered entity or a business associate under HIPAA, and nothing you keep in the App is a medical record.

21.1 Scope and applicability

This section applies to you if you live in a state whose law gives consumer health data protection of its own. Washington and Nevada are the clearest examples today. Those laws apply based on where you live, or where the data is collected, rather than on where we are.

They define consumer health data broadly. It is any information linked or reasonably linkable to you that identifies your past, present or future physical or mental health status. That is wider than medical records: it covers the measurements, logs and goals you keep in the App, and it covers inferences we draw from them, such as a calculated energy need.

21.2 Categories of consumer health data collected

The health and fitness information described in section 3.2 is consumer health data. In summary, we collect:

• body measurements: your sex, height, and current and recorded weights over time;
• goals and targets: activity level, goal type, calorie target, protein, carbohydrate and fat split, water target, step target and activity burn target;
• your food log: every food you log, the meal and day you logged it to, the serving and quantity, and its calories and macronutrients;
• your water log;
• your workouts: sessions, the exercises in them, and every set, including weight, repetitions, reps in reserve and whether it was completed;
• the plans, workout templates, custom exercises and recipes you build or save;
• any meal photograph you choose to submit, and the text of any question you send the assistant;
• your date of birth, which we hold to confirm you are 18 or over and to calculate your energy needs.

Two things are absent from that list because we never receive them. Apple Health readings, being your steps, active energy and heart rate, are read on your device and shown to you there, and are never transmitted to us. Your assistant conversation history is held on your device only. Section 4 sets out both in full, and section 9 covers Apple Health specifically.

21.3 Sources of the data

There is one source, and it is you. Every category listed above is information you enter into the App, or generate by using it.

We do not buy consumer health data. We do not obtain it from data brokers, advertising networks, public records, social networks or any other third party, and we do not derive it by tracking you across other apps or websites. Section 5 sets out what we do not collect.

21.4 Purposes for collection and use

We use consumer health data to run the features you are using it for, and for nothing else. Specifically:

• to record what you log and show it back to you;
• to calculate your energy needs and targets from your measurements and goals;
• to produce workout progressions and the other predictions the App makes;
• to synchronise your data between your own devices, and to restore it when you sign in again;
• to answer a support request you send us;
• to meet a legal obligation, or to establish, exercise or defend a legal claim.

We do not use consumer health data to advertise to you, and we do not use it to build a profile of you for anyone else. Section 12 describes how advertising works.

21.5 Sharing and disclosure of health data

We do not sell consumer health data. Under the My Health My Data Act, selling consumer health data requires your separate, signed authorisation. We do not seek that authorisation and we do not sell this data. This holds notwithstanding the general reservation in section 22, which does not apply to consumer health data.

We do not share consumer health data for cross-context behavioural advertising, and we do not disclose it to advertisers, advertising networks or data brokers.

We do disclose consumer health data to the service providers below, each of which processes it only on our instructions and for no purpose of its own:

• Supabase, which hosts our database and holds the health and fitness data that synchronises from your account;
• DigitalOcean, which runs our application server, through which food and recipe queries and assistant messages pass;
• FatSecret, which receives your search terms, any barcode you scan and any meal photograph you submit, in order to return food and recipe data;
• Google, which receives the text of a question you ask the assistant, and nothing else, in order to generate the answer.

We may also disclose consumer health data where the law requires it, or in the other circumstances described at the end of section 8. Where we do, we disclose the minimum necessary.

Section 11 permits us to create and commercialise de-identified and aggregated information. Information in that form is not consumer health data, because it does not identify you and cannot reasonably be used to identify you. We do not attempt to re-identify it.

21.6 How to exercise your health data rights

In addition to the rights in section 15, you have the right to:

• confirm whether we collect, share or sell your consumer health data;
• access that data, including a list of the third parties with which we have shared it;
• withdraw your consent to our collection and sharing of it;
• have it deleted, including from our backups and by the service providers we have shared it with.

To make a request, email somaticsfn@gmail.com, or write to Somatics, Incorporated, 3925 Newhall Drive NW, Hickory, North Carolina 28601, United States. Tell us which right you are exercising.

We will verify that the request is yours before acting on it, which normally means confirming that you control the phone number or email address on the account. We will respond within 45 days. If we need longer, we will tell you why within that period, and may take up to 45 further days. There is no charge, unless a request is manifestly unfounded or excessive, in which case we will tell you before doing anything.

If you ask us to delete your consumer health data, we will delete it from our systems and instruct the service providers listed in 21.5 to do the same. Deleting your account, as described in section 14, has the same effect once the 30-day grace period ends.

21.7 Appeals

If we refuse a request you make under 21.6, we will tell you in writing, explain why, and tell you how to appeal.

To appeal, reply to our decision, or email somaticsfn@gmail.com with the word Appeal in the subject line. An appeal costs nothing.

We will decide the appeal and write to you within 45 days of receiving it, and our response will explain the reasons for the decision. If we uphold our original refusal, we will also give you a way to complain to a regulator.

You may complain to the Attorney General of your state at any time, whether or not you have appealed to us first. For Washington residents that is the Washington State Attorney General, and for Nevada residents the Nevada Attorney General.

22. Reservation of rights

We reserve the right to revise, update, modify or replace this policy at any time, in our sole and absolute discretion, and to change how the App works and what it collects. Where the law requires your consent before a change takes effect, we will ask for it. Where the law requires notice, we will give notice in the App or by email and change the date at the top of this policy.

In particular, and without limiting the above, we may in future add or expand analytics and product measurement, add or change advertising and advertising measurement technologies, add or change the service providers listed in section 8, introduce new features that use information we already hold, and collect additional categories of information as the App develops. Continuing to use the App after a change takes effect means you accept the updated policy.

We may sell personal information, and may share it for cross-context behavioural advertising, as those terms are defined by California law and by the privacy laws of other states. Where we do, you have the right to direct us not to, and we will provide and honour the opt-out mechanisms those laws require, including a control for refusing the sale or sharing of your personal information and recognition of opt-out preference signals sent by your browser. We do not sell or share the Apple Health readings described in section 9, which never leave your device, and we do not sell or share personal information of anyone we know to be under 18.