Privacy Policy

Introduction

Please read this Privacy Policy (“Policy”) carefully before using our website accessible at fitflow.ai, including all pages and features (“Website), our application (“App”), and related services. The Website and the App (when it’s available) are operated by VitalCore USA Inc. (“Company”, “we”, “us” or “our”), having its registered address at:

142 W 57th street, New York, NY 10019, United States of America

To better protect your privacy, we provide this Policy explaining our privacy practices and the choices you can make about the way your information is collected and used by us. 

Your access to and use of our Website, App, and/or Services is conditioned upon your acceptance of and compliance with this Policy. This Policy applies to all visitors, users, and others who wish to access or use our Website, App, and/or Services. 

In addition to reviewing this Policy, please also review our Terms and Conditions, Cookie Policy, and any other terms and conditions that may be posted elsewhere on the Website, App, or otherwise communicated to our users. 

By accessing or using our Website, App, and/or Services, you (“you,” “your,” and “User”) agree to be bound by this Policy and our Terms and Conditions. If you disagree with any part of this Policy, Terms and Conditions, and Cookie Policy, then you do not have permission to access our Website, App, and/or Services. 

We will collect and use your Personal Information (as defined below) in ways that are described here, and in a manner that is consistent with our obligations and your rights under applicable data protection laws, including, but not limited to: 

  • General Data Protection Regulation (GDPR);
  • Data Protection Act 2018;
  • Children’s Online Privacy Protection Act (COPPA);
  • California Consumer Privacy Act (CCPA);
  • California Online Privacy Protection Act (CalOPPA);
  • California’s Shine the Light law;  
  • Personal Information Protection and Electronic Documents Act (“PIPEDA”);
  • Australian Privacy Principles (“APPs”) in the Privacy Act 1988 Australia;
  • Privacy Principles in the Privacy Act 2020 New Zealand, etc. 


For purposes of this Policy, “Personal Information” means any information relating to a living individual who can be identified from that information (or from that data and other information in our possession). 

All capitalized terms used in this Policy and not otherwise defined shall have the meanings provided for those terms in our Terms and Conditions.

Eligibility

You warrant and agree that you have the right and legal capacity to enter into these Terms and to adhere to them. You represent and warrant that you are at least 16 years old or have reached the legal age of majority as defined by the laws of your country of residence, where such majority age is required to access the Website, App, and/or Services.  If the law of your state/country requires us to obtain the consent of a parent or a legal guardian to process your Personal Information, you may not use our Website, App, and Services, and provide us with your Personal Information without such consent. 

Types Of Personal Information Collected By Us

We may collect, use, store, and transfer different kinds of Personal Information about you that we have categorized as follows: 

  • Information you provide: 
  1. contact information such as your name, email address, phone number, and address; 
  2. other information such as a birth date, password, billing information, credit card information, demographic information, your personal interests and background, gender, age, data on physical characteristics (such as weight, height, areas for improvement, etc.), fitness level, food and diet preferences, meditation preferences; 
  •  information about how you use our Website, App, and/or Services (the pages and profiles you view, how you browse the Services, and purchases you make through our Website, App, and/or Services);
  • information and content you upload (information about the content you upload, such as the time, date, and place the photo or content was taken or uploaded, and how you use them, who views them, or with whom you share them);
  • information automatically collected (your IP address, browser type, Internet service provider, platform type, the website or the app from which you came and the website or the app to which you are going when you leave our Website and/or App, date and time stamp and one or more cookies that may uniquely identify your browser or your account, the unique device ID, hardware ID, and Facebook ID, Apple Identifier for Advertising, Google AdID, device type, model and manufacturer, mobile device operating system brand and model, mobile carrier, phone number and email address);
  • your usage data concerning how you interact with our Website, App, and Services. For example, it can be information concerning your taps on certain areas of the interface, the features, and content you interact with, workouts you do, the time and duration of your workouts, how often you use our Website, App and Services, how long you are on the Website and/or in the App, your training program progress, your subscription orders, information about the ads in our Website and App with which you interact;
  • your communications with us and other users (such as emails and comments that you post on the pages we have on a third-party service);
  • location information;
  • information provided by others (we may collect information that third-party organizations may provide to us, such as contact details, demographic information, credit reference, fraud prevention information, updated payment information, or payment methods related to your paid account or paid subscription and services);
  • cookies and similar technologies. 

When law requires it, we obtain your consent before collecting your Personal Information. You may give us your consent electronically. You may also consent to the Company’s collection, use, and disclosure of your Personal Information by providing it to us in a clearly intentional manner (e.g., by accessing our Website or App, using our Services, submitting an information request, etc.). We may also rely on your implied consent to collect, use, and disclose your Personal Information where implied consent is permitted by applicable law. 

By voluntarily providing certain categories of Personal Information through our Website, App, and Services, you acknowledge and accept that such information may include sensitive Personal Information or special categories of Personal Information as defined under applicable data protection laws, including the CCPA and the GDPR. By choosing to share this information, you expressly provide your explicit, informed, and freely given consent for the collection, processing, use, and storage of such sensitive Personal Information. This processing is carried out for the purpose of enabling us to deliver personalized Services and content specifically tailored to your individual needs and preferences. 

If you choose not to provide certain Personal Information that is necessary for us to deliver our Services (for example, your name, contact details, or payment information), we may be unable to provide you with access to certain features or ensure the proper functioning of the Services. Your decision to withhold such information may result in limited functionality, restricted access, or our inability to fulfill your requests. 

The legal basis for processing your Personal Information includes your explicit consent, processing necessary to take steps at your request prior to entering into a contract or for the performance of a contract, the protection of vital interests, the performance of a task carried out in the public interest, our legitimate interests, provided they are not overridden by your fundamental rights and freedoms, and compliance with applicable legal obligations. 

Purposes Of Personal Information Use

We will use your Personal Information for: 

  • complying with applicable laws and regulations;
  • protecting legal rights and defending our interests and intellectual property;
  • providing you with the Services that you request from us;
  • complying with our obligations arising from any contracts entered into between you and us, or between you and our affiliates or service providers;
  • providing you with information about other products and services we offer;
  • fulfilling your requests for technical assistance, Service-related information, or any other communication that you initiate with us;
  • communicating with you regarding your use of our Website, App, and/or Services;
  • notifying you about changes to our Services;
  • quality assurance, and to record details about the Services you order from us;
  •  improving our Website, App, and/or Services;
  • maintaining security measures to safeguard our Website, App, and/or Services, and your Personal Information;
  • personalizing our advertisements; 
  • performing data analyses (including anonymization and aggregation of Personal Information);
  • enforcing our Terms and preventing and combating fraud. 

Do-Not-Track Signals

Our Website and App do not currently respond to “Do Not Track” (DNT) signals sent by browsers. To determine whether any of the third-party services we use recognize and respond to the “Do Not Track” signals, please read their privacy policies. 

How We May Share Your Personal Information

We may share the information we obtain with third parties, including but not limited to the following entities: 

  • our affiliates and subsidiaries; 
  • third parties as part of a potential merger, reorganization, asset transfer, or acquisition;
  • service providers (to provide services or handle transactions on our behalf, such as payment processing, email distribution, list processing, postal mailing, analytics, digital content, or print subscription performance measurement, ad serving);
  • providers of notification services;
  • providers of message and customer service tools;
  • cloud storage providers;
  • App Store developed by Apple Inc. (helps us to distribute our App);
  • Google Play is developed by Google LLC (a digital distribution service that helps us distribute our App);
  • advertisers, advertising- and marketing-related service providers and partners; 
  • Google Analytics – a web analysis service provided by Google LLC. Google utilizes the information collected to track and examine the use of our Services, and to prepare reports on their use. Google may use the information collected to contextualize and personalize the ads;
  • Hotjar is an all-in-one analysis and feedback tool that reveals the online behavior and feedback of Service users;
  • other analytical service providers which help us to understand how users use our Services, find us (for example, who was the advertiser that delivered an ad to users, which led you to an App Store with our App), to measure the effectiveness of some features of our Website, App, Services, and ads, etc.; 
  • as necessary to protect our rights (if it is necessary or appropriate to protect, enforce, or defend our legal rights, the privacy or safety of our employees, users of our Services or other individuals and entities, or to comply with or enforce applicable industry standards, law or legal process, including responding to court orders, warrants, subpoenas and other requests from public and government authorities); 
  • with your consent or otherwise at your direction. 

Links To Third-Party Websites

We do not review all of the pages which have links on our Website and/or App, and we are not responsible for the contents of any such linked pages. The inclusion of any link does not imply endorsement of such a website and/or service by the Company. Therefore, the privacy practices of these third-party websites and services can differ from ours. Use of any such linked website and/or services is at your own risk. We strongly recommend you read the privacy policies of all linked pages. 

Your Privacy Rights

Your data protection rights may vary depending on the laws and regulations applicable in your place of residence.

The European Economic Area and the United Kingdom privacy rights

If you are a resident of the European Economic Area or the United Kingdom, you have the following rights concerning collecting and processing your Personal Information: 

  • the right to object to the processing of Personal Information;   
  • the right to object to automated processing;    
  • the right to rectification of inaccurate Personal Information;
  • the right to withdraw previously given consent for the processing of Personal Information;
  • the right to access Personal Information;   
  • the right to receive Personal Information in a structured, commonly used, and machine-readable format and transmit it to another controller;   
  • the right to restriction of processing;    
  • the right to be informed about the Personal Information being processed;    
  • the right to the erasure of Personal Information;    
  • the right to lodge a complaint with a supervisory authority.
     

To exercise any of the available privacy rights, please send a request to [email protected]. If you have any concerns regarding our handling of your Personal Information and are not satisfied with our response, you may contact the UK Information Commissioner’s Office (ICO), contact details are available at https://ico.org.uk, or the data protection authority in your country of residence in the EU.   

Australia privacy rights

If you are a resident of Australia, you are entitled to the following rights regarding your Personal Information: 

  • the right to be informed about the categories of Personal Information the organization collect;
  • the right to know the purposes for which your Personal Information is collected;
  • the right to know the categories of third parties with whom your Personal Information has been shared or disclosed;
  • the right to access your Personal Information;
  • the right, in certain circumstances, to remain anonymous or use a pseudonym;   
  • the right to opt out of receiving unsolicited direct marketing communications;
  • the right to request correction of any inaccurate or incomplete Personal Information;  
  • the right to lodge a complaint regarding the handling of your Personal Information. 

If you have any concerns or complaints regarding the collection or handling of your Personal Information, please contact us at [email protected]. We will make every reasonable effort to address and resolve your complaint to your satisfaction. However, if you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC), which has the authority to further investigate the matter. Additional information about the Australian Privacy Act and the contact details of the Commissioner are available at www.oaic.gov.au. 

New Zealand privacy rights

If you are a resident of New Zealand, you are entitled to the following rights concerning your Personal Information: 

  • the right to be informed about the process, timeframe, and purposes for which your Personal Information is collected;
  • the right to know the consequences of not providing your Personal Information;
  • the right to access your Personal Information;    
  • the right to request correction of any inaccurate or incomplete Personal Information;  
  • the right to have your Personal Information used only for the purposes for which it was collected and to have it securely deleted or disposed of when no longer required;
  • the right to have your Personal Information used only when the organization has reasonable assurance that it is accurate and up to date;
  • the right to have your Personal Information stored and protected securely;
  • the right to lodge a complaint regarding the handling of your Personal Information. 

If you have any concerns or complaints regarding the collection or handling of your Personal Information, please contact us at [email protected]. We will make every reasonable effort to address and resolve your complaint to your satisfaction. However, if you are not satisfied with our response, you may contact the New Zealand Privacy Commissioner, who may investigate your complaint further. Further information about the application of the New Zealand Privacy Act, and how to contact the Commissioner, can be found at www.privacy.org.nz. 

Canada privacy rights

If you are a resident of Canada, you are entitled to the following rights regarding your Personal Information: 

  • the right to access your Personal Information;   
  • the right to have your Personal Information collected, used, and disclosed only upon the provision of your informed consent, except in specific circumstances where such consent is not legally required;
  • the right to have only the Personal Information necessary for clearly identified purposes collected;
  • the right to have your Personal Information maintained in an accurate, complete, and up-to-date form;
  • the right to ensure that the use, disclosure, and retention of your Personal Information are consistent with the purposes for which it was originally collected and that it is not retained longer than necessary;
  • the right to have your Personal Information protected by appropriate safeguards proportionate to its sensitivity;
  • the right to access information about the organization’s policies and practices concerning the management of Personal Information;
  • the right to request correction of any inaccurate or incomplete Personal Information;  
  • the right to file a complaint concerning the handling of your Personal Information. 

If you have any concerns or complaints regarding the collection or handling of your Personal Information, please contact us at [email protected]. If you are not satisfied with our response or the actions taken to address your concern, you may file a complaint with the Office of the Privacy Commissioner of Canada. Further information on how to contact the Commissioner is available at https://www.priv.gc.ca.   

California privacy rights

If you are a resident of California, you have the following rights with respect to your Personal Information: 

  • the right to receive notice of any actual or potential privacy breach with respect to your Personal Information;
  • the right to know the categories and the specific pieces of Personal Information we have collected about you;
  • the right to know the categories of Personal Information the Company has disclosed for a business purpose or has sold to third parties;
  • the right to know the categories of third parties to whom Personal Information was sold;
  • the right to know the categories of recipients to whom Personal Information was disclosed;
  • the right to opt-out of Personal Information sales or sharing to third parties;
  • the right to know the categories of sources of Personal Information;
  • the right to know the business or commercial purposes for collecting or selling Personal Information;
  • the right to request deletion of Personal Information we have collected from you, subject to certain exceptions;
  • the right to be free of discrimination for exercising these rights.

All of these rights are subject to certain conditions and exemptions.  For example, we will not be obligated to delete your Personal Information if we need to retain it to protect ourselves in the event of a legal claim. 

California’s Shine the Light law provides California residents with the right  to request information concerning: 

  • the Personal Information disclosed by us to third parties for the third parties’ direct marketing purposes during the immediately preceding calendar year;
  • the names and addresses of all third parties that received your Personal Information for direct marketing purposes during the previous calendar year. If the nature of the third party’s business cannot be reasonably inferred from their name, we will also provide examples of the products or services that the third-party markets.

California residents may make a request pursuant to their rights under the CCPA and California’s Shine the Light law by contacting us at [email protected] or by sending your request to:

142 W 57th street, New York, NY 10019, United States of America

Cookie Usage

We use cookies to collect specific information when you interact with our Website and/or App. This information helps us deliver relevant advertisements and improve our Services. For more information about the technologies we use and how to manage cookies, please refer to our Cookie Policy. 

Miscellaneous

We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our Website and/or App; any transmission is at your own risk. Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorized access. In the event of a breach involving your Personal Information, we will notify you in accordance with applicable laws. 

The information that we collect from you may be stored, processed, and transferred to any country where we, our affiliates, or our processors have facilities.  In cases where the destination country does not offer an adequate level of protection for Personal Information, the transfer will only take place following the conclusion of particular agreements between us and the said subjects, which will include safeguard clauses and/or appropriate safeguards for the protection of your Personal Information. By submitting your Personal Information, you agree to this transfer, storage, and processing.  We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy. Unfortunately, the transmission of information via the Internet is not completely secure. 

Personal Information shall be processed and stored for as long as required by the purpose it has been collected and according to applicable laws. Personal Information collected for purposes related to the performance of a contract between the Company and you shall be retained until such contract has been fully performed. Personal Information collected for the purposes of our legitimate interests shall be retained as long as needed to fulfill such purposes. In certain instances, such as for public interest archiving, scientific or historical research, or statistical analysis, your Personal Information may be stored for extended periods. In these cases, we will implement appropriate technical and organizational measures to protect your rights and freedoms. 

Changes To This Policy

We may revise this Policy at any time without notice. We will publish the revised Policy on our Website and/or App. By continuing to use our Website, App, and/or Services, you agree to be bound by the new version of this Policy. 

Contact Us

If you have any questions about this Policy and/or our Terms and Conditions, please contact us at [email protected]. 

REVISED: 06/2025