GetFZKL · Legal

Privacy Policy

Last updated: 24 August 2026

Source document: Download original .docx — the authoritative version signed off by the legal team.

Privacy Policy

Our Privacy Policy was last updated on 24.08.2026

  1. The Purpose of this Privacy Policy

This Privacy Policy has been developed to protect the privacy, confidentiality, security, secrecy, safety unity and integrity of the Personal Data of users of the GetFZKL mobile application, in accordance with the best international standards and practices.

The provisions of this Privacy Policy shall apply to the processing of Your Personal Data while using GetFZKL mobile application, whether totally or partially, through automatically operated electronic systems or other means.

The Company may process account data, contact data, subscription data, technical data, usage data, food and meal data, activity data, body metrics, health-related information, photos, support messages, consent logs and security records for the purposes described below.

Some processing is necessary to provide the Service, manage accounts, process subscriptions, maintain security, prevent abuse, respond to requests and comply with legal obligations. Other processing, such as optional analytics, marketing, certain tracking technologies, advertising use of photos or testimonials, or certain sensitive data uses, may require a separate consent or setting depending on applicable law.

We ensure Your Personal Data is kept securely and protected from any breach, infringement, illegal or unauthorized processing. The Company establishes technical and organizational measures and procedures in accordance with the best world practices.

The provisions of this Policy are binding on employees, counterparties of the Company, as well as third parties lawfully engaged by the Company who have access to Your Personal data.

This Policy applies to relations regarding processing and protection of Your Personal Data while using GetFZKL mobile application, which means that:

  • You confirm and acknowledges that You have carefully reviewed this Policy and the terms of processing of Your Personal Data in full.

  • The text of this Policy and the terms of Personal Data processing are clear to You.

  • You confirm full consent to this Policy and to the terms of processing of Your Personal data.

  • Your consent to Personal Data processing is provided to the Company and is express, specific, informed, conscious, and unambiguous. Where applicable law requires consent for a specific processing activity, the Company will request consent in a clear and reasonably prominent manner.

Your consent to Personal Data processing is considered granted when You perform actions that clearly indicate Your intention to use the GetFZKL mobile application and Services and to transfer Personal Data to the Company, including performing all or some of the following actions:

  • Acceptance of the Terms and Conditions, including payment for access to the functionality of the GetFZKL mobile application and Services.

  • Completing forms, questionnaires, and other fields requiring entry of Personal data, as well as sending Personal Data in the course of using the GetFZKL mobile application and Services.

The Company retains confirmations of the fact that You granted consent (including technical event logs, interface marks, date and time, session identifiers) within the time periods necessary to confirm the lawfulness of processing and to protect the rights and legitimate interests of the Company. If separate consent is required for certain purposes or categories of data, processing for such purposes is carried out provided that You grant separate consent in the form specified by the Company.

The Company will make key privacy information available at or before the point of collection where reasonably possible, including through short onboarding notices, consent forms, privacy settings, subscription pages, feature notices and this Policy.

If You do not agree with the terms of this Policy, You must discontinue using the GetFZKL mobile application and Services.

The Services are intended for persons who have reached the age of eighteen (18) years. If You have not reached the specified age, You must refrain from using the GetFZKL mobile application and Services and from providing Personal Data. The Company has the right to request age confirmation and, if such confirmation is not provided, to restrict access to the GetFZKL mobile application and Services.

This Policy applies only to the GetFZKL mobile application. The Company does not control and is not responsible for third-party websites to which You may navigate via links available in the GetFZKL mobile application. The Company is not responsible for Personal Data processing by third parties that obtain access to such data not through the GetFZKL mobile application and Services, including cases where You independently disclose Personal Data to an indefinite number of persons, including by publication in open sources or by forwarding to third parties. The Company is also not responsible for the consequences of You navigating to external resources access to which is provided via links in the GetFZKL mobile application, since such resources operate outside the Company’s control. Limitation of liability applies to the extent permitted by applicable law.

The Company does not verify the accuracy of Personal Data provided by You.

You confirm that You provide Personal Data accurately and in relation to You, and that You have the necessary rights and consents to provide the Company with any materials and information that You post in the GetFZKL mobile application, including photo and video materials. You undertake to refrain from sending to the Company Personal Data of third parties without a proper legal basis and without the consent of such persons. If any claims, demands, or lawsuits are brought against the Company by third parties due to Your breach of this obligation, You undertake to assist in settlement and to compensate the Company for documented losses to the extent permitted by applicable law.

  1. Definitions

As used in this Privacy Policy, the following terms shall have the following meanings:

The Company, We, Us: FIZIKL IQ-FZCO – a company, including any of its employees, representatives, or agents, which provides remote informational support and familiarization with available nutrition and training programs for natural persons (the “Service”). For the purpose of this Privacy Policy, the Company is the Data Controller.

Client: any natural person who has reached the age of eighteen (18) years and accesses or uses the GetFZKL mobile application and Service. For the purpose of this Privacy Policy, the Client is the Data Subject.

Application: GetFZKL mobile application.

Service: services being provided by giving access to the GetFZKL mobile application, as well as the functionalities of the GetFZKL mobile application itself, including personal food tracking, physical activity tracking and generation of personal nutrition and activity plans and any other services, offered by the Company to its Clients. The Services are delivered based on AI functionality without any human involvement to the extent permitted by this Privacy Policy and applicable law.

Device: a mobile phone, a computer or any other device with a web browser through which a Client can access the GetFZKL mobile application and Service.

Personal Data: any information relating to an identified or identifiable natural person (the “Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Sensitive Personal Data: information relating to an identified or identifiable natural person (the “Data Subject”) and is treated as sensitive, special category, health-related or otherwise specially protected under applicable law. This may include health information, physical condition data, body metrics, nutrition information that reveals health status, pregnancy or lactation information, menstrual cycle information, medication intake, injury or limitation information, genetic or biometric data, precise geolocation, government identifiers, financial information, race, religion, sex life, sexual orientation, gender identity, children’s data, and any other category treated as sensitive by applicable law. The Company does not sell Sensitive Personal Data and does not use Sensitive Personal Data for advertising purposes unless a separate legally valid consent or another lawful basis applies.

Data Subject, You: any Client who has reached the age of eighteen (18) and whose Personal Data are stored and processed under this Privacy Policy. The Company does not collect and/or process any Personal Data of persons under the age of eighteen (18).

Processing: any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Automated Decision-Making Technology (ADMT): any technology that processes personal information and uses computation to replace human decisionmaking or substantially replace human decisionmaking.

Data Controller: the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Data Processor: means any natural or legal person who processes Personal Data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

Counterparty: a third-party natural or legal person engaged by the Company for the purposes of Service provision, or to perform related services, including, but not limited to, analysis of the Service usage.

Cookies and Similar Technologies: cookies, mobile SDKs, device identifiers, pixels, tags, scripts, local storage, analytics tools, attribution tools and similar technologies that store information on or access information from Your Device or Application environment.

Privacy Settings: the Application or account settings area, where available, allowing You to review or change certain privacy choices, consents, marketing preferences, analytics choices, push notification choices, photo analysis choices or similar settings.

Confidentiality Incident: any access, use, disclosure, loss or other incident involving Personal Data that may be unauthorized, unlawful or inconsistent with this Policy, including a data breach, security incident or similar event under applicable law.

Calendar day: a period of twenty-four (24) hours in accordance with the time zone of the Data Subject’s country of residence, which includes all days, both working days and weekends and holidays, in accordance with applicable law.

Business day: a period of twenty-four (24) hours in accordance with the time zone of the Data Subject’s country of residence, which includes all days that are not weekends or public holidays, in accordance with applicable law.

  1. Purposes of Personal Data Processing

The Company may process or ensure of processing of Personal Data for the following purposes:

To provide and maintain our Service, including provision of personal food tracking, physical activity tracking and generation of personal nutrition and activity plans, informational remote support, provision of other services chosen by You.

To manage Your Account: to manage Your registration as a user of the Service and give You access to different functionalities of the Service that are available to You as a registered user.

To contact You: to contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as the GetFZKL mobile application's push notifications, regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide You with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.

For marketing (advertising) purposes: to promote services and the brand in the market by conducting marketing communications, stimulating sales, and targeting, including by publishing materials on websites, in social networks, and in messengers of the project and its partners, provided that You grant separate consent where such consent is required by applicable law.

For subscription and payment administration: to process purchases, manage trials, renewals, cancellations, refunds, chargebacks, receipts, fraud prevention, App Store interactions and payment-related support. The Company does not store full payment card details unless expressly stated otherwise.

For consent, preference and compliance records: to record the text, version, language, date, time, user identifier, device or session identifier and status of consents, refusals, withdrawals and privacy settings, where necessary to demonstrate compliance and manage user choices.

To manage Your requests: to attend and manage Your requests to Us.

To monitor the behavior of the target audience: to collect data about such audience, and to conduct marketing research, including determining the effectiveness of advertising campaigns.

To prevent fraud and abuse: to identify violations of the Terms and Conditions, to ensure investigation of incidents, to conduct claim and litigation work, and to implement the rights and legitimate interests of the Company and/or third parties in connection with the use of the GetFZKL mobile application and Services.

For other purposes: We may use Your Personal Data for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, other products, marketing, and Your experience.

For specific purposes or if consent is required under the applicable laws and regulations, We may ask Your consent for processing of Your Personal Data. In those jurisdictions in which consent is the legal basis of processing, You provide such consent by agreeing to use the Service. We hereby inform You, and You hereby acknowledge, that You have no legal obligation to provide Us with any Personal Data, and such provision is solely based on Your free will. However, You also acknowledge that without the provision of Personal Data, We will not be able to provide You with the Service or Your use of the GetFZKL mobile application will be limited.

We may share Your Personal Data in the following situations:

With Counterparties: We may share Your Personal Data with our Counterparties to provide the Service, to perform related services, to monitor or analyze the use of our Service (analytical services), to process Your payments (payment services), or to contact You (i.e., email or SMS marketing).

With affiliates or agents: We may share Your Personal Data with Our affiliates or agents; in which case we will require those affiliates and agents to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

With other users: when You share personal information or otherwise interact in the public areas (chat groups, etc.) with other users, such information may be viewed by all users and may be publicly distributed outside.

  1. Types of Data Collected

The Company may process or ensure of processing of the following types of Personal Data:

  • General information, including full name; date of birth; age; gender (if applicable); goals; language; time zone.

  • Mobile telephone number.

  • Email ID.

  • Your daily habits.

  • Your body parameters, such as Your height; weight; Body Mass Index (BMI); circumferences of Your waist, hips, chest, neck, biceps, lower arm, lower leg, ancle etc.

  • Your activity level, such as information about number of steps; type, length and intensity rate of exercising.

  • General physical state, such as hunger; level of energy; sleeping habits; level of stress.

  • Nutrition habits, such as calories and energy value; dietary habits.

  • State of health, such as illness; pregnancy and lactation period; menstrual cycle; GLP-1, hormonal drugs and other medicine intake.

  • Photo and video materials provided by You, including those containing Your images.

  • Information about Your behavior in the GetFZKL mobile application (behavioral statistics), collected based on Your identifiers and/or analytics counters. Other identifiers and information about Your use of the GetFZKL mobile application and Services, including the Internet Protocol (IP), the time of registration and/or visiting the GetFZKL mobile application and Services, Your geolocation data, the interface language, and other similar data.

  • Technical journals (logs) of actions in the GetFZKL mobile application and Services, information about security events, information about consents and refusals, requests to the support service, and the content of correspondence with the Company to the extent necessary for reviewing requests, settling claims, and protecting the rights and legitimate interests of the Company.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g., IP address), the pages of our Service that You visit, the time and date of Your visit, Your geolocation, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a Device, We may collect certain information automatically, including, but not limited to, the type of Device You use, Your Device unique ID, the IP address of Your Device, Your mobile operating system, unique Device identifiers and other diagnostic data.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless You have adjusted Your Device settings so that it will refuse Cookies, our Service may use Cookies.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal mobile device when You go offline, while Session Cookies are deleted as soon as You close the Application.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies

Type: Session Cookies

Purpose: These Cookies are essential to provide You with services available through the Application and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

  • Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Purpose: These Cookies identify if users have accepted the use of cookies on the Application.

  • Functionality Cookies

Type: Persistent Cookies

Purpose: These Cookies allow us to remember choices You make when You use the Application, such as remembering Your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter Your preferences every time You use the Application.

  • Tracking and Performance Cookies

Type: Persistent Cookies

Purpose: These Cookies are used to collect information and track information about user activity in the Application. The information gathered via these Cookies may directly or indirectly identify You as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device You use to access the Application. We may also use these Cookies to test new pages, features, or new functionality of the Application to see how our users react to them.

In this Policy, references to Cookies include Cookies and Similar Technologies used in mobile applications, including SDKs, device identifiers, pixels, tags, analytics modules, crash reporting tools, attribution tools and similar technologies.

Strictly necessary technologies may be used without optional consent where they are required for account login, security, fraud prevention, subscription management, remembering privacy settings, core app functionality or technical operation of the Service.

Non-essential analytics, tracking, attribution, advertising, profiling or similar technologies will be used only where permitted by applicable law and, where required, after the User has given valid consent through an interface notice, consent banner, privacy settings or another appropriate mechanism.

The User may withdraw or change optional tracking choices through Privacy Settings, device settings, operating system permissions, browser settings or other tools made available by the Company or the relevant platform, where technically available.

  1. Principles of Personal Data Protection

Processing must be made in a fair, transparent, and lawful manner.

Personal Data may be collected for the purposes stated in this Privacy Policy and may not be processed in a manner incompatible with such purposes. Personal Data may be processed if the purpose of processing is similar or close to the purpose for which such data are collected.

Personal Data shall be sufficient for and limited to the purpose for which the processing is made.

Personal Data must be accurate and correct and must be updated whenever necessary.

Personal Data must be kept securely and protected from any breach in accordance with other principles set by this Privacy Policy.

  1. Sources of Personal Data

The sources from which the Company collects Personal Data may include:

  • our Clients,

  • our Counterparties,

  • other third parties, assuming that they provide their Personal Data or Personal Data of other persons with their express consent,

  • publicly available registers or sources of information, etc.

  1. Transfer of Your Personal Data

Your Personal Data may be stored and maintained on — or transferred to — computers located outside of Your jurisdiction, and the data protection legislation may differ from those of Your jurisdiction.

Your information may be transferred to the country or territory which has adequate level of data protection determined by the UAE authorities or to the country that the UAE is entered to bilateral or multilateral agreements related to Personal Data protection.

In case the country or territory is not deemed by the UAE authorities as the country or territory with adequate level of data protection, but in order to provide You with the Service or to serve other purposes of Personal Data processing there is a necessity of such cross-border transfer, Your information may be transferred to those countries or territories under the Company’s obligation to ensure the level of data protection set out by the UAE legislation. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to such transfers.

The Company will take all steps reasonably necessary to ensure that Your Personal Data is treated securely and in accordance with this Privacy Policy. If You are located in a jurisdiction where transfer of Your Personal Data to another jurisdiction requires Your consent, then Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to such transfers.

  1. Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if it is required by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation.

  • Protect and defend the rights or property of the Company.

  • Prevent or investigate possible wrongdoing in connection with the Service.

  • Protect the personal safety of users of the Service or the public.

  • Protect against legal liability.

  1. Technical and Organizational Measures

Owing to the functionality of the Application, the processing of Your Personal Data is carried mainly automatically.

The Company shall take the appropriate technical and organizational measures and procedures to apply the necessary standards to protect and secure Personal Data in order to maintain its confidentiality and privacy and to ensure that it is not infringed, damaged, altered, or tampered with, taking into account the nature, scope, and purposes of processing, and the potential risks to the confidentiality and privacy of the Personal Data.

The Company shall ensure that the processing of Personal Data is limited to its intended purpose(s).

The Company shall apply appropriate measures, both when defining the means of processing and during the processing itself, in order to comply with the applicable data protection legislation and provisions of this Privacy Policy.

In case of appointment of Processor(s), the Company shall ensure that such Processor(s) provides sufficient guaranties to apply technical and organizational measures in a manner that ensures that the processing meets the provisions of this Privacy Policy, as well as requirements, rules, and principles stipulated in the applicable Personal Data protection legislation.

The Company shall not take any action that would disclose the Personal Data or the results of processing, except in cases permitted by the applicable law or this Privacy Policy.

The Company shall comply with other obligations arising from this Privacy Policy or the applicable Personal Data protection legislation.

The security of Your Personal Data is important to Us but remember that no method of transmission via the Internet, or method of electronic storage is 100 percent secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Where requirements of the applicable laws apply to the Company and such requirements provide territorial restrictions for localization of Personal Data of citizens / residents the particular countries, the Company arranges the recording, systematization, accumulation, storage, and clarification of such Personal Data using databases located on the particular territories to the extent required by applicable law and consistent with the service delivery model.

  1. Detailed Information on the Processing of Your Personal Data

Our Counterparties, affiliates, and agents have access to Your Personal Data only to perform their tasks on our behalf and are obligated not to disclose or use it for any other purpose.

You give Your express consent to the transfer (provision) by the Company of Your Personal Data to third parties (partners, agents, subcontractors and other third parties engaged by the Company on a lawful basis) to achieve the purposes provided for in the Privacy Policy, for the provision of services to You by the Company, and in other cases provided for by applicable law.

Our third-party Counterparties, affiliates, and agents collect, store, use, process, and transfer Your Personal Data in accordance with their privacy policies in the following situations:

Service Provision

We may use third-party Counterparties, affiliates, or agents to provide the Service or to perform related services.

Analytics

We may use third-party Counterparties to monitor and analyze the use of our Service or the Application. For this purpose, We may use:

Metabase,

Google Analytics,

Firebase,

Cloud Message,

Amplitude,

Sentry,

RevenueCat,

AppsFlyer.

Email or SMS Marketing and Information Communication

The Company has the right to interact with You through the GetFZKL mobile application or other means of communication by sending notifications, reminders, and other informational messages, as well as notifications about new products, services, promotions, special offers, and various events of the Company. You have the right to opt out of receiving advertising messages at any time. The opt-out may be realized:

  • By sending the Company a notice to the email ID: support@getfzkl.com, indicating in the subject line: “Opt out of receiving notifications about new products, services, promotions, special offers, events”.

  • By using opt-out tools provided in the interface of the GetFZKL mobile application (including mailing list management buttons) where such tools are available.

  • By disabling push notifications in the device settings if messages are sent via the push channel.

Opting out of advertising messages does not restrict You from access to the GetFZKL mobile application and Services, except where the inability to send messages makes performance of the contract or fulfillment of the Company’s obligations under applicable law impossible.

Certain components of the GetFZKL mobile application, including advertising modules, may be provided by third parties. Such persons may use their own data collection technologies, including cookies and pixels. The Company does not control the technologies and policies of such third parties and is not responsible for their actions outside the Company’s information systems. You have the right to restrict such technologies via browser settings, device settings, and content blocking tools.

Payments

We may provide paid products and/or services within the Service or the Application. In that case, we may use third-party services for payment processing (e.g., payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policies. The payment processor that We use is Apple (In-App Purchase). In some cases We may use any other payment processors, that adhere to the standards set by PCI DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI DSS requirements help ensure the secure handling of payment information.

The Client who is the Data Subject confirms that their consent to Personal Data processing is given in a clear, simple, and unambiguous manner.

If a Client provides (disclose) Personal Data of another Data Subject, this Client guarantees that they have the prior consent of the Data Subject for such disclosure.

Data Subject may, at any time, withdraw their consent to the processing of their Personal Data. Such withdrawal shall not affect the legality and lawfulness of the processing made based on the consent given prior to such withdrawal.

  1. Automated Decision-Making Technology (ADMT)

We may use ADMT to provide You with personalized nutrition tracking, with artificial intelligence (the “AI”) for recognizing food from photographs and calculating individual daily calory and nutrient targets, as it is the main purpose of Our Services and assured by the functionality of the Application.

General AI functionality of Our Application

The Application:

  • Allows the user to log meals using AI photo recognition: the user takes a picture of food, and the Application identifies the dish and calculates calories, protein, fat, carbohydrates, and fiber;

  • Automatically calculates individual daily targets (calories, protein, fiber, steps) based on the user’s data: sex, age, height, weight, body composition, training activity, and goal;

  • Adapts targets every week based on actual behavior: weight trend and real activity. A missed day is not a reason for anxiety; the algorithm adjusts to You calmly;

  • Shows a safe dashboard: bars as “progress toward the target,” with no red colors, no notifications about “calories remaining,” and no binary “good/bad” framing.

Food recognition by photograph (AI)

The Application offers a single way to add food - AI recognition from a photo:

  • The user taps “+” (on the main screen or in the diary), and the camera opens;

  • The user takes one or more photos of the meal;

  • AI recognizes dishes in real time (results appear as processing is completed);

  • The user can add a text description to the entry bar;

  • The application automatically calculates calories, protein, fat, carbohydrates, and fiber;

  • The entry is saved in the diary, and the user returns to the main screen.

Editing an entry: the user can adjust portion weight, and the nutrients will be recalculated proportionally. The dish can also be moved to another meal (breakfast / lunch / dinner / snack).

Target calculation algorithm

The application automatically calculates daily targets based on the data collected during onboarding:

What is calculated:

  • Daily calorie target;

  • Daily protein target (grams);

  • Daily fiber target (grams);

  • Daily step target.

Based on:

  • Sex, age, height, current weight;

  • Body fat percentage (selected by the user or calculated from circumferences);

  • Training activity (types, hours, progress);

  • Number of steps per day;

  • Type of work;

  • Target weight and selected mode (loss / maintenance / gain).

Weekly adaptation:

  • Once a week, the algorithm analyzes the weight trend and actual activity;

  • Targets are adjusted smoothly and calmly, without sudden jumps or warning-style notifications;

  • The user sees a gentle update notification on the main screen.

Warning system (safety guardrails):

  • If the weight goal is too low for the current body composition: a warning and recommendation to consult a specialist;

  • If weight gain is too rapid after weight loss: a gentle prompt;

  • If the user is underweight: recommendation to consult a doctor.

The Company does not intend to use ADMT to make decisions that produce legal effects or similarly significant effects on You. If the Company ever uses Personal Data to make a decision based exclusively on automated processing in a way that materially affects You, the Company will provide any notice, explanation, access, correction, review, contestation, observations or human review rights required by applicable law.

Automated outputs may be inaccurate or incomplete. You may update inputs, correct meal entries, adjust portions, change goals, disable optional features where available, withdraw relevant consent, request information about automated processing, or contact the Company for support.

If a decision is made exclusively on the basis of automated processing and applicable law requires notice or access to the main factors and parameters that led to the decision, the Company will provide such information upon request to the extent required by law and technically feasible.

  1. Legal Basis of Personal Data Processing

The Company has taken appropriate measures to ensure Personal Data is processed according to applicable data protection laws.

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.

  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.

  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.

  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will help You to clarify the specific legal basis that applies to the processing, and whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

  1. Your Rights under this Privacy Policy

The Company undertakes to respect the confidentiality and privacy of Your Personal Data and to guarantee You can exercise Your rights.

Under this Privacy Policy, You have the following rights:

  • Request access to Your Personal Data. The right to access, update, or delete the information We have on You. Whenever made possible, You can access, update, or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of Your Personal Data We hold.

  • Request correction of Your Personal Data that We hold. You have the right to have any incomplete or inaccurate information We hold about You corrected.

  • Restrict processing of Your Personal Data. This right exists where We are collecting and process Sensitive Personal Data, if any, and there is something about Your situation which makes You want to object to our processing of Your Sensitive Personal Data on this ground. You have the right to restrict Sensitive Personal Data Processing at any time by sending Us a notification to the email ID: support@getfzkl.com, indicating in the subject line: “Limit the Use of My Sensitive Personal Information”.

  • Request the erasure of Your Personal Data. You have the right to ask Us to delete or remove Your Personal Data when there is no good reason for Us to continue processing it.

  • Request the transfer of Your Personal Data. We will provide to You, or to a third party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format if such transfer is technically possible. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

  • Withdraw Your consent. You have the right to withdraw Your consent on using Your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to the Service or its certain specific functionalities. You may withdraw Your consent at any time by sending Us a notification to the email ID: support@getfzkl.com, indicating in the subject line: “Withdrawal of Personal Data Processing Consent”.

  • Right to opt out of Sale or Sharing of Personal Data. Sharing refers specifically to sharing for cross-context behavioral advertising, which is the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s online activity. You have the right to opt out of Sale or Sharing of Personal Data at any time by sending Us a notification to the email ID: support@getfzkl.com, indicating in the subject line: “Do Not Sell or Share My Personal Information”.

  • Right to opt out of use of ADMT. We may use ADMT to provide You with personal food tracking, physical activity tracking and generation of personal nutrition and activity plans, as it is the main purpose of Our Services. We do not use ADMT to make significant decisions affecting Your rights and interests. You have the right to restrict the use of ADMT by sending Us a notification to the email ID: support@getfzkl.com, indicating in the subject line: “Opt-out of ADTM”. However, You should kindly note that in case of opt out of ADTM We may not be able to provide You with access to the Service or its certain specific functionalities.

  • Right of access to information about ADMT. You have the right to information about how ADMT is used, including the logic involved and the significance of the output by sending Us a notification to the email ID: support@getfzkl.com, indicating in the subject line: “Access to information about ADMT”.

  • Any other rights under applicable data privacy laws.

  1. Exercising of Your Rights

You may submit requests and notifications to the Company to the email ID: support@getfzkl.com. The request must contain information enabling identification of the Personal Data subject and the subject’s connection to the account, including full name, contact telephone number and/or email ID, as well as a description of the request. The Company has the right to request additional information to verify the applicant’s identity and to prevent unlawful disclosure of personal data. The time limits for reviewing requests are determined by applicable law; the time limit is fifteen (15) business days from the date of receipt of the request, unless a different period is required by applicable law or unless additional time is reasonably required due to complexity, verification, third-party involvement or legal exceptions. The Company has the right to refuse to satisfy the request in full or in part if the request does not relate to Personal Data processed by the Company, or if the Company cannot identify the applicant, or if satisfying the request would violate the rights and legitimate interests of third parties, in the cases and within the limits permitted by applicable law. The Company sends a reasoned response indicating the legal basis for refusal or indicating actions required to identify the applicant.

  1. California Privacy Disclosures

California consumers have a right to knowledge, access (including information about ADMT), correction, and deletion of their Personal Data under the California Consumer Privacy Act. California consumers also have a right to opt out of the sale or sharing of their Personal by the Company, to opt out of use of ADMT, to restrict processing of Sensitive Personal Data (if any) and a right not to be discriminated against for exercising their California privacy rights and in response their to privacy rights requests.

California consumers can exercise their rights directly or through an authorized agent by submit requests to the Company to the email ID: support@getfzkl.com, as specified in Section 14 of this Privacy Policy.

  1. Retention of Data

The Company shall only retain the Personal Data for as long as it is necessary to fulfill the purpose for which it was collected.

The Personal Data will typically be retained by the Company for the required duration of the relevant Services provision unless such information is or may be otherwise required to be retained for a longer period by any applicable laws or regulations, in which case such Personal Data shall be retained for the required period.

Indicative retention approach: account and subscription records are retained for the account term and a reasonable period after closure for legal, tax, accounting, fraud prevention and dispute purposes; consent logs and privacy request records are retained for the period necessary to demonstrate compliance; support and complaint records are retained for the period necessary to resolve the matter and manage legal risk; security logs are retained for a limited security and investigation period unless needed longer for an incident or claim.

Backups may retain Personal Data for a limited additional period according to backup cycles, provided that access is restricted and data is deleted or overwritten according to the backup retention schedule unless a legal hold applies.

If the purpose for processing Your Personal Data no longer applies, we will delete Your Personal Data as soon as it is technically possible and within reasonable time taking into account amounts of Your Personal Data to be deleted.

When deleting Personal Data, the Company takes steps to remove the data from active databases within a reasonable time; however, certain information may be retained in backups and event logs for a limited period necessary to ensure information security, restore systems and verify the lawfulness of the Company’s actions. Once this period has elapsed, the backups are either updated or destroyed.

  1. Dispute Resolution

Before filing a lawsuit regarding disputes arising from relations between You and the Company regarding the Personal Data processing, the interested party sends the other party a written claim. The claim is sent in the form of a signed scanned copy to the relevant email ID: for You, to the email ID provided by You during registration in the Application; for the Company, to the email ID: support@getfzkl.com.

The claim must contain the essence of the request, circumstances, justification, calculation of the recovery amount (where applicable), and contact details for response. A claim sent to an email ID is considered received on the date it is delivered to the interested party’s mail server.

The period for responding to a claim is ten (10) business days from the date of its receipt. If all the above conditions are not met, the claim procedure is not considered complied with.

If no agreement is reached, the dispute is submitted to a competent court determined in accordance with the jurisdiction rules imposed by the mandatory provisions of the Data Subject’s country of residence.

Nothing in this dispute resolution Section prevents You from submitting a complaint to the competent privacy, data protection, consumer or electronic marketing authority where applicable law gives You that right.

  1. Changes

This Policy may be amended by the Company unilaterally in full or in part without prior notice to You. The new version of the Policy enters into force from the moment it is posted in the Application, unless otherwise provided by the new version of the Policy.

The current Policy is posted in the GetFZKL mobile application.

The new version of the Policy applies to Personal Data received by the Company both before and after such new version enters into force.

The Company has the right to inform You about amendments to the Policy by posting a notice in the GetFZKL mobile application. Continued use of the Services after the new version of the Policy enters into force means that You agree with the new version of the Policy to the extent permitted by applicable law.

  1. Contact Us

If You have any further questions, concerns, or complains in relation to our use of Your Personal Data, please do not hesitate to email our contact person Viktoriia Orleanskaia by submitting Your requests at info@physical-transformation.com.

FIZIKL IQ-FZCO,

Registered in Dubai Silicon Oasis, Techno Hub 2, 66th Street, Nr 20, I132-H, Nad Al Hessa, Dubai, the UAE. License Number: 32779.