Privacy Policy

This Privacy Policy describes how Membri ("we," "us," or "our") collects, uses, and protects your information when you use GainFrame (an AI progress-photo app that estimates body composition scores and tips for fitness tracking). By using the app, you agree to this Policy.

1. About GainFrame

GainFrame provides:

• Front and side photo scans
• Body fat and muscle score estimates with tips
• Progress charts, timelines, and reminders

2. Information We Collect

2.1 Personal Data

We collect only what is necessary to operate GainFrame. Most data stays on your device. We do not sell your personal information.

• Progress photos may be sent to AI providers to generate estimates.
• Estimates are educational wellness tools, not DEXA, medical, or diagnostic results.
• We do not sell your personal data.

2.2 Usage Data

We may collect device type, operating system, app version, crash logs, and anonymized usage statistics to improve stability and performance. Optional diagnostics, where offered in the app, load only if you opt in.

2.3 Support Communications

When you contact us through the support form, we collect the information you provide to respond to your request.

3. How We Use Your Information

• Provide, maintain, and improve GainFrame
• Generate body composition estimates from photos you upload
• Process subscriptions via Apple and Superwall
• Respond to support requests
• Comply with legal obligations

4. Legal Basis for Processing (EEA, UK, and Switzerland)

Where GDPR or similar laws apply, we process personal data based on:

• Performance of a contract, providing the Service you requested (including AI estimates from content you submit)
• Legitimate interests, maintaining and securing the Service, preventing abuse
• Consent, optional analytics or diagnostics, optional health integrations, and other processing that requires a choice
• Compliance with legal obligations, responding to lawful requests

5. Third-Party Services

We may share data with service providers that help us operate the app, including:

• Apple, App Store purchases and subscriptions
• Superwall, Subscription management (Privacy Policy)
• OpenAI, When you use AI features, your inputs (including photos or text) may be sent to OpenAI to generate a result. See OpenAI's Privacy Policy.

We do not sell your personal data to third parties or share it for cross-context behavioural advertising.

6. International Data Transfers

We operate from Spain and may process data using servers or service providers located in other countries (including the United States, where OpenAI processes AI requests). When transferring personal data internationally, we rely on appropriate safeguards, such as Standard Contractual Clauses, to protect your rights.

7. Data Retention and Deletion

We retain data only as long as needed to provide the service or comply with law. On-device data remains until you delete it or uninstall the app. You may request deletion of data we hold via the support page. Where GDPR applies, we respond within one month.

8. Your Rights

Depending on your location, you may have the right to:

• Access, Request a copy of your personal data
• Rectification, Correct inaccurate data
• Erasure, Request deletion of your personal data
• Portability, Receive your data in a portable format
• Objection, Object to or restrict certain processing
• Withdraw consent, Where consent is the legal basis, without affecting processing before withdrawal

To exercise these rights, use the support form. We may need to verify your identity and can refuse requests that are excessive, unfounded, or restricted by law.

9. Data Security

We use technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, or alteration. No online service is completely secure; keep your device and software updated.

10. Children's Privacy

GainFrame is not directed to children under 17. We do not knowingly collect personal information from children below this age.

11. California Privacy Rights

If you are a California resident, you have the right to know the categories of personal information we collect, use, and disclose, as described above, and to request deletion, subject to CCPA exemptions. We do not sell or share personal information for cross-context behavioural advertising.

12. EU/EEA Supervisory Authority

If you reside in the European Union, you may lodge a complaint with your local data protection authority. We are established in Spain; the Spanish authority is the Agencia Española de Protección de Datos (AEPD). Other authorities are listed at edpb.europa.eu.

13. Changes to This Policy

We may update this Policy from time to time. Material changes will be reflected by updating the "Last updated" date. Continued use of GainFrame after changes means you accept the updated Policy.

14. Contact

Controller: Membri, Spain.
Questions or data requests: GainFrame support form. See also our Terms of Service or membri support.

Where GDPR applies, we will respond within one month.