Fitara: Privacy Policy (UK)

Product: Fitara (formerly JS Coach), for Personal Trainers & Clients
Operated by: JS Technology Group
Effective: 3 June 2026  ·  Last updated: 30 September 2026  ·  Version: v1.1

This is the UK privacy policy for Fitara. A US version covering CCPA / MHMDA requirements applies when a tenant is operated in the United States. This document is written to the ICO's privacy-policy checklist and UK GDPR Articles 13 and 14 disclosure requirements.

Who we are

Fitara is operated by JS Technology Group, a UK-based software company. JS Technology Group provides the platform (the mobile app, the backend, the licensing service, and the admin web interface); your personal trainer ("PT") or their business operates the tenant within which your data lives.

For most questions about your data, contact your PT directly — they are the party with the trainer-client relationship and control the day-to-day handling of your information. For platform-wide questions (security, deletion, breach response), contact JS Technology Group.

Joint controllership: Under UK GDPR, JS Technology Group and your PT (or their business) act as joint controllers of your personal data. We have a written arrangement that splits responsibilities:

You may exercise your rights against either party — neither will refer you to the other to avoid answering.

Contact:

What personal data we collect, and where it comes from

CategoryExample dataSource
IdentityEmail, display name, date of birthYou enter when you sign up
AuthenticationPassword (hashed; we never see plaintext), TOTP code (if you enable two-factor)You set during account creation
Food intakeMeals you log: name, weight, calories, macros, meal slot, notesYou enter, or your PT enters on your behalf
Body weight + compositionWeight, body fat percentage, measurement dateYou enter, or read from Apple Health or Google Health Connect (with your permission)
Activity + sleepDaily step count; sleep start/end and deep/REM minutes; distance travelled; active energy and total energy burned; resting heart rateRead from Apple Health or Google Health Connect (with your permission) or entered by you
Exercise plans + workoutsPlans your trainer authors for you; sets/reps/weights you log during sessions; workout sessions recorded by your phone or watchYour PT authors; you log; or read from Apple Health or Google Health Connect (with your permission)
Check-in photosPhotographs you take at regular check-ins for body-composition trackingYou take in-app; optional — you control whether this category is enabled
Medical notes / allergiesInformation you choose to share with your trainer about conditions, medications, allergies, etc.You enter — optional and your choice what to include
GoalsBody composition / performance goals you discuss with your trainerYou enter
Device + auditDevice identifier, app version, IP address (when you connect), timestamps of actionsCaptured automatically when you use the app

We do not collect: precise location, contacts, browsing history, advertising identifiers, behavioural fingerprints, or social-network data.

Why we process your data, and our lawful basis

Under UK GDPR, every type of processing must have a lawful basis. Ours:

PurposeLawful basis (Article 6)Special-category condition (Article 9)
Providing the Fitara service (contract with your trainer)Article 6(1)(b) — performance of a contractArticle 9(2)(a) — your explicit consent, per data category
Enabling your trainer to coach you (sharing your data with them)Article 6(1)(b)Article 9(2)(a) — your explicit consent (the share_with_trainer toggle)
Aggregate reporting for the tenant operatorArticle 6(1)(f) — legitimate interests in business operationn/a — aggregates only
Account security, audit, fraud preventionArticle 6(1)(f) — legitimate interests (security) and Article 6(1)(c) — legal obligation (Article 32)n/a
Responding to your data subject rights (DSAR, erasure)Article 6(1)(c) — legal obligationArticle 9(2)(g) where rights involve special-category data
Marketing communications (only with separate opt-in)Article 6(1)(a) — consentn/a

You see the per-category consent toggles when you first set up your account, and you can change them at any time in Settings → Privacy. Withdrawing consent for a category stops further processing of that category from the moment of withdrawal. For check-in photos specifically, withdrawing consent triggers immediate cryptographic deletion of all your existing photos.

Who we share your data with

Sub-processors

We use a small number of sub-processors to deliver the service:

A full sub-processor list is available on request.

International transfers

At v1, all your data stays in the UK / EU. The platform's tenant_config.data_region is pinned to eu_uk for all UK tenants.

Where a sub-processor (e.g. Firebase) operates outside the UK / EU, the transfer is covered by the EU Standard Contractual Clauses + the UK International Data Transfer Addendum. Encrypted data leaves the UK / EU only inside cryptographic envelopes that JS Technology Group controls — the sub-processor cannot read your data unilaterally.

How long we keep your data

CategoryRetentionWhen deleted
Your account + profileWhile your account is active, plus a 30-day grace after closureOn account deletion or 12 months of inactivity
Food, weight, step, sleep logsWhile your account is activeOn account deletion or when you request erasure
Check-in photos12 months by default (your trainer's tenant may set a shorter retention)On photo deletion, consent withdrawal, or retention timer
Audit log entries (about your actions)6 years from the actionRetention timer
Records of data subject requests6 years after fulfilmentRetention timer
Backups35-day rotationRotational ageing

The 6-year audit retention follows ICO recommendation for health data processing — it lets us investigate incidents and demonstrate compliance.

Your rights under UK GDPR

You can exercise these rights in two ways: directly in the app (Settings → Privacy for most rights), or by contacting JS Technology Group or your trainer.

RightWhat it meansHow to exercise
Be informed (Art. 13)This privacy policy is the disclosure.Read this document.
Access (Art. 15)Request a copy of all the personal data we hold about you.Tap Settings → Privacy → Export My Data. We aim to deliver within 14 days; legal limit is 1 month.
Rectification (Art. 16)Correct inaccurate or incomplete data.Edit data directly in the app for self-managed fields; contact your trainer or use Settings → Privacy → Request Correction for trainer-managed fields.
Erasure (Art. 17)Request deletion of your data.Tap Settings → Privacy → Delete My Account. We crypto-shred photos and logs immediately; backups age out within 35 days.
Restriction (Art. 18)Pause processing of your data while a dispute is resolved.Contact privacy@jstechnologygroup.co.uk.
Portability (Art. 20)Receive your data in a portable JSON format.The DSAR Export delivers a structured JSON export.
Object (Art. 21)Object to processing based on legitimate interests (audit / security).Contact privacy@jstechnologygroup.co.uk. We may not be able to discontinue security-related processing — Article 32 requires it.
Withdraw consent (Art. 7)Withdraw your consent for any data category.Tap Settings → Privacy → Per-category consent. Effect is immediate.
Lodge a complaintComplain to the ICO if you believe your rights are being infringed.https://ico.org.uk/concerns/ or +44 303 123 1113.

We respond to most rights requests within 14 days (well inside the 1-month statutory limit).

Children's data

Fitara is for adults only. You must be 18 or older to create an account. We collect date of birth at signup, and accounts indicating an age below 18 are rejected. We do not knowingly process data of children under 18.

If you believe a child has signed up using a misrepresented DOB, contact privacy@jstechnologygroup.co.uk and we will investigate and delete the account.

How we secure your data

If you discover a vulnerability, please report it to security@jstechnologygroup.co.uk. We will investigate promptly and have a documented incident response process.

Marketing

You will not receive marketing communications from us by default. Marketing push notifications and emails are separately opt-in and visible as their own consent category in Settings → Privacy. If you opt in and later wish to stop, untoggle the consent — effect is immediate.

Service notifications (e.g. "your trainer assigned you a new plan", "check-in reminder") are not marketing and are not affected by the marketing consent.

Cookies + similar technologies

The mobile app does not use browser cookies. The admin web interface (used by tenant operators) uses one strictly-necessary cookie for session management (pt_session_refresh). No analytics cookies, no marketing cookies, no third-party cookies.

Changes to this policy

We will notify you of material changes via in-app banner + the next time you sign in. The current version of the policy is the version displayed in Settings → Privacy → Privacy Policy at any given moment.

How to contact us, and how to complain

Want toContact
Ask about your dataYour trainer first; or privacy@jstechnologygroup.co.uk
Exercise a data subject rightSettings → Privacy in the app, or privacy@jstechnologygroup.co.uk
Report a security concernsecurity@jstechnologygroup.co.uk
Lodge a formal complaintInformation Commissioner's Office: https://ico.org.uk/concerns/ — +44 303 123 1113

Version history

VersionDateChange
v1.03 June 2026Initial published version.
v1.130 September 2026Product renamed from JS Coach to Fitara. No change to what data is collected, the lawful bases, retention, or your rights.