Privacy Policy

Overview

P.R.O. is a fitness tracking and performance analytics application. This Privacy Policy describes personal data processing by HAOTONG TECHNOLOGY (HK) CO., LIMITED for the P.R.O. app and website, and by Dorokhov Daniil for the optional MCP connector described in Part C.

This policy is organized into three parts:

• Part A — Standard app usage (account creation and core fitness tracking)
• Part B — Optional AI-powered features
• Part C — Optional AI assistants and connectors (MCP)

Part A applies to all users. Part B applies additionally if you choose to use AI features in the app. Part C applies additionally if you connect P.R.O. to a third-party AI assistant such as Claude, ChatGPT, Codex or Grok. If there is any conflict, Part B prevails with respect to the in-app AI coach and Part C prevails with respect to connected AI assistants.

Data Controller — app and website: HAOTONG TECHNOLOGY (HK) CO., LIMITED

Data Controller — MCP connector (Part C): Dorokhov Daniil, Armenia

Privacy Contact: mail@proapp.uk

Part A — Standard App Usage

A1. Data We Collect

Registration data: Name, email address, password (hashed), date of birth, biological sex (optional), height and weight (optional).

Technical data: Device type, OS version, app version, anonymized crash reports, and session timestamps.

A2. Legal Basis for Processing

A3. Data Sharing

We do not sell your personal data. We share data only with:

• Infrastructure providers (e.g., cloud hosting) — under contractual data protection obligations, for hosting and storage
• Product analytics and monitoring — PostHog (EU region) receives usage events such as which feature or API was used, linked to a pseudonymous account ID and, for connector requests, the IP address; Langfuse (EU region) receives monitoring data about AI requests (see Part B). Neither receives your Apple Health data for analytics or advertising, and neither may use it for its own purposes
• Self-hosted product analytics — our own OpenPanel instance (not a third party) receives app and website usage events through our server: screens and actions in the app, pages and clicks on proapp.uk, your account email and name, a random installation or visitor ID, device model, OS and app version, and the IP address with the approximate location derived from it. It is used to find problems and improve P.R.O., is never used for advertising, and is erased when you delete your account, apart from the account deletion summary described in A5
• Legal requirements — if compelled by applicable law, court order, or regulatory authority

We require all third-party service providers to maintain appropriate technical and organizational security measures. However, we cannot guarantee the security practices of third parties and disclaim responsibility for breaches or data incidents occurring within their systems.

A4. Security

All data is encrypted in transit (TLS 1.3) and at rest (AES-256). Access is restricted to authorized personnel. While we implement industry-standard security measures, no system is entirely immune to unauthorized access. We disclaim liability for security incidents resulting from circumstances beyond our reasonable control, including but not limited to third-party infrastructure failures.

A5. Retention

• Account and fitness data: retained while your account is active; deleted within 30 days of account deletion
• Technical and crash logs: retained for 90 days, then automatically purged
• Account deletion summary: from November 18, 2026, when you delete your account, we first create a summary of how P.R.O. was used and keep it for up to 12 months, to understand why people leave and improve the app. It covers things like how long the account was used, app version and device model, language, how you signed in and where you came from, which features were used and the last actions in the app, whether purchases were started, the subscription tier, and the number and type of errors and crashes. It does not contain your name, email, account ID, IP address, health or fitness values, or the text of your messages, and times in it are relative, with the date recorded only as a calendar week. We do not use it to identify you or to contact you

We are not able to guarantee deletion of data already shared with third-party infrastructure providers within the same timeframe, as their own retention policies apply.

Part B — AI-Powered Features

B1. How AI Features Work

AI features in P.R.O. rely on independent third-party AI infrastructure. Depending on the model you select:

• Auto mode — requests are sent via OpenRouter, an independent third-party AI API aggregation service, to a model chosen by P.R.O. If OpenRouter is unavailable, the request is sent directly to Nvidia NIM (Nvidia Inference Microservices) as a backup.
• Training plans and metric analysis — always sent via OpenRouter to a fixed model chosen by P.R.O., whatever model you selected for chat.
• Other models — requests are sent via OpenRouter, which routes the request to the selected backend AI model provider.

P.R.O. displays the returned response to you. AI computation is performed entirely by the applicable third-party provider (OpenRouter and its backend model providers, or Nvidia NIM as a backup), which are independent services not operated by HAOTONG TECHNOLOGY (HK) CO., LIMITED.

B2. Data Transmitted

Before any data is sent to a third-party AI provider, P.R.O. processes it on our systems — for example, selecting only the fitness context relevant to your query, applying pseudonymization where applicable, and preparing the request payload. Only this processed data is transmitted externally; your full account profile is not sent as-is.

When you use an AI feature, the following processed data may be transmitted externally:

• Your text query (the input you provide)
• A limited selection of fitness context data necessary for the AI feature to function
• A pseudonymous session identifier (does not include your name or email)

B3. Third-Party AI Processors

Nvidia NIM (backup for Auto mode)

When Auto mode falls back to Nvidia NIM, P.R.O. transmits processed data directly to Nvidia NIM. P.R.O. has a service relationship with Nvidia for this purpose; however, Nvidia's data retention, storage, logging, and model training practices are governed entirely by Nvidia's own privacy policy and are outside P.R.O.'s control or responsibility.

OpenRouter

OpenRouter routes requests to various backend AI model providers. P.R.O. has a service relationship with OpenRouter; however, P.R.O. does not have direct contractual relationships with OpenRouter's backend providers and therefore cannot guarantee, enforce, or be held responsible for the data practices of those providers.

Backend AI Model Providers

Backend model providers are independent third parties. Their data retention, storage, logging, and model training practices are governed entirely by their own privacy policies and are outside P.R.O.'s control or responsibility. P.R.O. expressly disclaims liability for any processing, storage, disclosure, or use of data carried out by backend AI model providers.

Relevant policies:

• Nvidia: nvidia.com privacy policy
• OpenRouter provider data practices: openrouter.ai/docs/guides/privacy/provider-logging

Langfuse (AI monitoring)

Langfuse acts only on our instructions and does not use this data for its own purposes. Requests made by AI assistants through the connector (Part C) are not sent to Langfuse.

B4. Retention of AI Data

P.R.O. keeps your AI conversation history in the app on your device for your reference. You can delete it at any time in the chat history: swipe a conversation to delete it, or clear all conversations. On our servers we store only coach notes, short facts you or the coach chose to remember (for example an injury or your available equipment), until you delete them or your account. Monitoring records of AI requests are kept by Langfuse as described above.

Nvidia NIM, OpenRouter, and backend model providers retain data per their own policies. P.R.O. has no ability to control, limit, or compel deletion of data once transmitted to those services.

B5. International Data Transfers

Nvidia NIM, OpenRouter, and their backend providers may process data on servers in jurisdictions outside your country of residence, including the United States. P.R.O. relies on these providers to implement appropriate transfer safeguards where required. P.R.O. makes no representation and accepts no liability regarding the transfer mechanisms or data localization practices of individual AI providers.

B6. Opting Out

AI features are entirely optional and can be disabled at any time in Settings → AI Features. Disabling AI features does not affect access to any other part of the app. Withdrawal of consent does not obligate P.R.O. to retrieve or delete data already transmitted to third-party providers prior to withdrawal.

B7. AI Output Disclaimer

AI-generated content provided through P.R.O. is for informational and advisory purposes only. It does not constitute medical, clinical, nutritional, or professional fitness advice. HAOTONG TECHNOLOGY (HK) CO., LIMITED makes no warranty as to the accuracy, completeness, or reliability of AI-generated outputs. Use of AI features and reliance on AI-generated content is at the user's sole risk.

Part C — AI Assistants and Connectors (MCP)

C1. What the Connector Is

The optional connector based on the Model Context Protocol (MCP) at https://mcp.proapp.uk is operated by Dorokhov Daniil, an independent developer based in Armenia. HAOTONG TECHNOLOGY (HK) CO., LIMITED remains the operator of the P.R.O. app and website. The connector lets a third-party AI assistant that you choose, such as Anthropic Claude, OpenAI ChatGPT, Codex or Grok, read your permitted P.R.O. data so it can answer questions about your training, sleep and goals in its own chat. The connector is off until you set it up, and you can use P.R.O. without it. Setup instructions are on the connector guide.

C2. How a Connection Is Authorized

• The assistant connects through OAuth 2.1 with dynamic client registration. You never give the assistant your P.R.O. password.
• To approve a connection, you generate a one-time six-character pairing code in the P.R.O. app (Settings → MCP Connect → Get connection code). The code is valid for 10 minutes and can be used once.
• No data is shared before you type that code on the P.R.O. authorization page. Once you do, the assistant receives access tokens tied to your account.

C3. What the Assistant Can Read

The assistant reads data only when you ask it something in that assistant and it decides to use the connector to answer. Depending on the categories you allow, it can read:

Detailed data on request. Sleep stages and the heart-rate curve and splits of recent workouts are part of the regular sync listed above. Anything beyond that is uploaded only on request: when you ask for more detail about one day or one workout, or when the assistant shows the P.R.O. workout card, the assistant can ask your iPhone to upload a full-day heart-rate series, the stages or splits of an older night or workout, or a workout GPS route. The upload happens only after you open the P.R.O. app, and only for categories you allow. These detailed uploads are cached on our servers for 48 hours so that a repeated question does not upload them again; after 48 hours they expire, are no longer available to any assistant and are deleted.

C4. What the Assistant Can Do

• Save a coach note, only if you turned on Allow saving coach notes in the app. This setting is off by default. A new note can supersede an earlier active note; earlier versions are retained.
• Suggest training plan changes. Suggestions are saved as pending proposals. They do not change your plan until you accept changes in P.R.O. A new proposal supersedes older pending proposals.
• Request a fresh sync, which asks the P.R.O. app to upload new Apple Health data the next time you open it.

The connector cannot delete data, make payments, send messages on your behalf or change your account settings.

C5. Your Controls

• Granular permissions. In Settings → MCP Connect → Data the assistant can read you can switch off any category (profile, goals, daily metrics, workouts, workout routes, sleep, heart rate and HRV, coach memory). Saved changes apply to the next connector request. A switched-off category is not returned to any connected assistant, and the assistant is told that you turned it off.
• Coach-note writing is off by default. Saving notes requires Allow saving coach notes. Pending plan proposals are separate from this switch and require your acceptance in P.R.O. before changing the plan.
• Disconnecting. In the app, open Settings → MCP Connect. Under Connected, tap × beside an assistant and confirm Disconnect. This blocks that assistant's next connector request. Removing the P.R.O. connector in the assistant's own settings alone does not revoke its access. Changes to permissions or connections cannot retrieve data already returned to the assistant.
• Account deletion. Deleting your account (Settings → Delete Account) deletes your data on our servers, including connector tokens, pairing codes and cached detailed uploads, and revokes all connector access.

C6. Who Receives the Data

To fulfil your connector requests, the P.R.O. data you permit is processed by Dorokhov Daniil as the MCP operator and returned to the AI assistant you connected. HAOTONG TECHNOLOGY (HK) CO., LIMITED remains responsible for processing data in the P.R.O. app. The assistant is operated by an independent third party (for example Anthropic, OpenAI or Perplexity AI). Once data reaches the assistant, its storage, retention, use and any model training are governed by that provider's own terms and privacy policy, which you accepted when you signed up for it. Review them before connecting:

• Anthropic (Claude): anthropic.com/legal/privacy
• OpenAI (ChatGPT): openai.com/policies/privacy-policy
• Perplexity: perplexity.ai/hub/legal/privacy-policy

In line with Apple App Store Review Guideline 5.1.2(i), we disclose here that personal data, including health and fitness data, is shared with these third-party AI services, and we ask for your explicit permission through the pairing code before any data is shared.

C7. What We Do Not Do

• We do not sell your data or share it for third-party advertising.
• We do not use health or fitness data for advertising, marketing or data mining, in line with Apple App Store Review Guideline 5.1.3.
• We do not use your data to train AI models.
• We share connector data only with the assistant you connected, and only to answer your requests.

C8. Not Medical Advice

P.R.O. and the connector provide wellness and fitness information only. P.R.O. is not a medical device, and nothing an assistant says based on P.R.O. data is medical advice, diagnosis or treatment. Talk to a qualified healthcare professional about medical questions and before starting or changing a training programme.

Your Rights

Regardless of jurisdiction, you may contact us to:

• Access, correct, or delete the data we directly hold about you
• Export your data (JSON or CSV)
• Withdraw consent for AI features, connected AI assistants or marketing communications
• Lodge a complaint with your local data protection authority

Please note: Rights relating to data held by third-party providers (Nvidia NIM, OpenRouter, backend AI model providers, AI assistants you connected through the P.R.O. connector, infrastructure providers) must be exercised directly with those providers. P.R.O. cannot fulfill data access, correction, or deletion requests on behalf of independent third-party processors.

EU/EEA users: Rights under GDPR Articles 15–22 apply to data controlled by HAOTONG TECHNOLOGY (HK) CO., LIMITED. For downstream processors, you may need to contact them directly or your national supervisory authority.

California users: Rights under CCPA/CPRA apply to data held by HAOTONG TECHNOLOGY (HK) CO., LIMITED. We do not sell personal data. For third-party processors, please refer to their respective privacy policies.

To exercise your rights with P.R.O.: mail@proapp.uk — we respond within 30 days.

Limitation of Liability

To the maximum extent permitted by applicable law, HAOTONG TECHNOLOGY (HK) CO., LIMITED disclaims all liability for:

• Data processing, storage, disclosure, or use carried out by Nvidia NIM, OpenRouter, or any backend AI model provider
• Security incidents, data breaches, or unauthorized access occurring within third-party systems
• Inaccurate, incomplete, or harmful AI-generated outputs
• Service interruptions, errors, or failures in third-party AI infrastructure

Our aggregate liability under this policy shall not exceed the greater of (a) the fees paid by the user in the twelve months preceding the claim, or (b) USD $100.

Changes to This Policy

Material changes are published on this page at least 14 days before they take effect. Continued use of the app after the effective date constitutes acceptance of the revised policy. The "Last Updated" date at the top of this document reflects the most recent revision.

Contact

mail@proapp.uk