PT Paul Personal Training Pte Ltd ("we", "us", "our") operates AdaptFit.AI (the "App"). We are committed to protecting your personal data in accordance with the Singapore Personal Data Protection Act 2012 (PDPA), as amended in 2020.
This Privacy Policy applies to all users of AdaptFit.AI globally. By using AdaptFit.AI, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal data as described here.
PT Paul Personal Training Pte Ltd
Singapore
Data Protection Officer: paul@adaptfit.ai
Available during Singapore business hours (SGT, UTC+8). We respond within 30 days.
The following is classified as sensitive personal data under Singapore's PDPA and is handled with the highest level of protection.
This data is collected from connected wearable devices or Apple HealthKit only when you have explicitly granted permission, and is used solely to personalise your coaching.
You may optionally provide additional sensitive health information including life stage (menopause, perimenopause, pregnancy, postnatal status), hormonal health considerations, or relevant medical conditions. This is:
If you indicate pregnancy or postnatal status, we record your explicit informed consent to exercise, including timestamp and the specific statements you agreed to. These records are retained as a legal safety audit trail in anonymised form for 7 years as required by applicable law.
Device type and operating system version, app version number, anonymised crash reports, and app usage timestamps. We do not collect GPS location, contacts, browsing history, or any data unrelated to your fitness coaching.
| Data Type | Legal Basis |
|---|---|
| Profile and account data | Contractual necessity — to provide the coaching service |
| Health and biometric data | Explicit consent — obtained at wearable connection |
| Sensitive health notes | Explicit consent — voluntary, clearly labelled |
| Prenatal/postnatal consent records | Legal obligation — safety audit trail |
| Training session data | Contractual necessity — core service function |
| AI coaching interactions | Legitimate interest — personalising coaching quality |
| Technical/crash data | Legitimate interest — maintaining App stability |
You may withdraw consent at any time by contacting paul@adaptfit.ai or deleting your account.
We use your data to: deliver personalised coaching sessions; generate AI coaching responses via PT Paul; track your training progress and personal bests; protect your safety by detecting overtraining patterns; adapt training for hormonal health or pregnancy where you have provided this information; enable wearable integrations; enable Strava posting if you have connected and authorised this; and improve the App using anonymised aggregate data.
We do not use your data for: advertising, selling to third parties, insurance purposes, employment screening, or any purpose not described in this Policy.
AdaptFit.AI uses Anthropic's Claude AI to generate PT Paul coaching responses. When you interact with the App, relevant contextual data is sent to Anthropic's API.
Data sent to Anthropic may include: your fitness goals and experience level, current session details, recovery status (green/amber/red — not raw biometric values), RPE data, and any health context directly relevant to your query.
Anthropic's obligations: processes data solely to generate your response; does not retain data beyond the immediate API request; does not use your data to train AI models without consent; acts as a data processor under our written Data Processing Agreement.
For full details: anthropic.com/privacy
Important: AI coaching responses are for general fitness guidance only and do not constitute medical advice.
Health metrics are read with your explicit permission. We comply with Apple's HealthKit requirements, which prohibit using HealthKit data for advertising or selling to third parties.
If connected, we access recovery, sleep, and HRV data via the Whoop API using OAuth 2.0. We store only access tokens — never your Whoop credentials. Disconnect anytime from Profile.
If connected, we post completed sessions to your Strava feed. We do not read your Strava history. Disconnect anytime from Profile → Sharing & Social.
Exercise video content provider. Only exercise category and equipment data is sent — no personal health data or identifying information.
Data storage provider. Data is stored in Singapore (ap-southeast-1 region). Supabase holds SOC 2 Type II and ISO 27001 certifications.
We do not share your personal data with advertisers, data brokers, analytics companies, or marketing platforms. We do not sell your data in any form. We do not share aggregated or de-identified data with third parties for commercial purposes.
Your data is primarily stored in Singapore. When data is sent to Anthropic's API for AI coaching, it may be processed on servers outside Singapore. We ensure compliance with Section 26 of the PDPA (Transfer Limitation Obligations) by engaging only processors who provide comparable data protection standards and maintaining Data Processing Agreements with all third-party processors.
Technical measures: encryption in transit (TLS 1.3), encryption at rest (AES-256), row-level security on all database tables, additional encryption for sensitive health notes, access tokens stored in iOS Secure Enclave (Keychain), API keys stored server-side only.
Data Breach Notification: In the event of a notifiable data breach, we will notify the Personal Data Protection Commission (PDPC) within 3 calendar days as required by Part 6A of the PDPA, and notify affected users promptly.
| Data Category | Retention Period |
|---|---|
| Profile and account data | Until account deletion |
| Training session logs | Until account deletion |
| Health metrics and biometric data | Until account deletion |
| Sensitive health notes | Until user deletes or account deletion |
| Prenatal/postnatal consent records | 7 years, anonymised — legal requirement |
| AI coaching conversation logs | 30 days |
| Anonymised crash reports | 90 days |
| Anonymised aggregate usage data | Indefinitely |
| Right | How to Exercise |
|---|---|
| Access — request a copy of your data | Email paul@adaptfit.ai |
| Correction — request correction of inaccurate data | Profile screen or email |
| Deletion — request deletion of your data | In-app delete or email |
| Withdrawal of consent | Email paul@adaptfit.ai |
| Data portability — request machine-readable format | Email paul@adaptfit.ai |
| Complaint — lodge with the PDPC | pdpc.gov.sg |
We respond to all requests within 30 days. We will never discriminate against you for exercising your privacy rights.
In-app: Profile → App → Delete my account and data
This permanently deletes your profile, all training history, health metrics, health notes, AI conversation history, and connected device integrations. Prenatal/postnatal consent records are retained for 7 years in fully anonymised form with all identifying information removed.
AdaptFit.AI is intended for users aged 18 and over. We do not knowingly collect personal data from persons under 18. If you believe a minor has provided us with personal data, contact paul@adaptfit.ai immediately.
We may update this Privacy Policy from time to time. We will notify you of material changes via in-app notification. Continued use after changes constitutes acceptance of the updated Policy.
PT Paul Personal Training Pte Ltd
Data Protection Officer
Email: paul@adaptfit.ai
Website: adaptfit.ai
Personal Data Protection Commission Singapore
pdpc.gov.sg · +65 6377 3131
This Privacy Policy is governed by the laws of Singapore. Version 1.1, May 2026.