Privacy Policy
This policy explains which personal data element47 processes, on what legal basis and for how long. It is written to be read, not endured.
Last updated:
In short
- The data you enter (profile, plans, sessions) is there to make the app work for you, and it stays yours.
- Usage statistics stay off until you turn them on. Crash reports start out active, and you can switch them off whenever you want.
- The content of your plans and the data about your health are not used for statistics, do not go to advertising and are not sold to third parties.
- Your data is hosted in the European Union, and today program generation runs there too.
- You can delete your account and data directly from the app.
Data controller
The data controller is Silver Studio, developer of the element47 application (identifier me.silverstudio.element47).
For any matter concerning your data you can write to the contact address at the bottom of this page.
What data we process
Account data. Email address and user identifier, created when you sign up. If you sign in with Google or Apple, we receive the identifier and the email address from the provider (which, with Apple, you can choose to mask).
Training profile. The data you enter so that a program can be built for you: experience level, goals, days available, equipment, any injuries or limitations, and — if you provide them — age, sex, weight and height. Some of these fall under health data: we process them only on the basis of your explicit consent and for the sole purpose of generating and adapting your workouts.
Content you create. Plans, programs, logged sessions, loads, reps, notes and custom exercises.
Technical data. Device model, operating system, app version, language and the technical identifiers needed to run the service and protect it from abuse.
Usage data — only with your consent. Usage events: which screens you open, when you generate or complete something.
Error and crash diagnostics. The technical context of a crash — device, version, point in the code — not what you write inside the app. It is active by default because it is what keeps the service standing, and it can be switched off in settings.
What we never process for statistics
The content of your plans and programs, and the data concerning your health, do not enter usage statistics. We do not use them for advertising and we do not sell them to anyone.
The free text you write about injuries is not sent to the artificial-intelligence model: only rounded values and predefined labels reach generation.
Why we process it, and on what basis
To provide the service (Art. 6(1)(b) GDPR): account, synchronisation, plans, logging and history.
With your consent (Art. 6(1)(a) and Art. 9(2)(a) GDPR): the health-related data used to build programs, and usage statistics. Consent can be withdrawn at any time in settings, without affecting the lawfulness of processing already carried out.
On a legitimate interest (Art. 6(1)(f) GDPR): infrastructure security, abuse prevention, service continuity, and error and crash diagnostics. For that last one you have a switch anyway, in settings.
Statistics and crashes: two separate switches
On first install, usage statistics are off. The app asks you once, explicitly, and until you answer nothing goes out.
Crash reports are instead active by default: they collect the technical context of a crash, not the content you write, and they exist so that anyone notices the app broke before you have to tell us. We process them on the legitimate interest of keeping the service standing.
The two switches are separate and can be flipped at any time, from settings in the Profile tab.
Generation with artificial intelligence
When you ask for a program to be generated or regenerated, the app sends a structured, reduced version of your profile to a server-side service: level, goals, available equipment, limitation categories, and a numeric summary of your recent workouts.
Processing takes place on the infrastructure of a cloud provider — today Google Cloud, in the European Union. Should a feature in future require a different region or a different provider, the transfer would take place under the safeguards described below and this page would be updated first. The content sent is not used to train third-party models.
The model picks exercises and structure within a closed library; loads, progressions and safety limits are computed by deterministic code, not by the model.
Who processes data on our behalf
We rely on Google Ireland Limited and Google LLC for infrastructure (authentication, database, server functions, storage, diagnostics and — if you consent — usage statistics) and for the artificial-intelligence models that generate programs, as data processors. If we changed provider for one of these functions we would update this page.
Some processing may involve a transfer to the United States, covered by the EU-US Data Privacy Framework and the standard contractual clauses.
Where the data is and for how long
Data is hosted on infrastructure in the European Union (region europe-west1). The possible exception is AI generation processing: see the dedicated section above.
We keep the data for as long as your account exists. When the account is deleted, the personal data associated with it is erased; some technical backup copies may persist for a limited period before rotation, and security logs for as long as their purpose requires.
Your rights
You may at any time request access, rectification, erasure, restriction and portability of your data, and object to certain processing (Arts. 15–22 GDPR).
The fastest route to erasure is inside the app: delete the account from settings. For everything else, write to the contact address.
You also have the right to lodge a complaint with the supervisory authority of your Member State — in Italy, the Garante per la protezione dei dati personali.
Minors
element47 is not intended for anyone under 16: that is the age the GDPR sets for consenting on your own to an online service, and no Member State may require a higher one. It therefore applies everywhere, with no per-country exceptions.
If we become aware of an account created below that age, we delete it.
Changes to this policy
If the processing changes we update this page and the date at the top. When the change is substantial we flag it inside the app.