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Privacy Policy & Terms of Service

Effective Date: March 3, 2026

A note on this website: when you load protocol-health.de, our hosting provider (Render Services, Inc.) and its CDN subprocessor (Cloudflare, Inc.) process server log data such as your IP address, time of access, the page requested and the user agent, on the basis of Art. 6(1)(f) GDPR; logs are deleted after 30 days at the latest. This website sets no cookies and uses no analytics or tracking. The document below governs the Protocol Health App and related services.

Protocol Health GmbH, HRB 282672 B, Berlin Charlottenburg

Welcome to Protocol Health. This document sets out both the Privacy Policy and Terms of Service that govern your use of the Protocol Health mobile application and related services (collectively, the "App"). By creating an account or using the App, you agree to be bound by this document in its entirety. If you do not agree, please do not use the App.

Protocol Health is operated by Protocol Health GmbH, registered under HRB 282672 B at the district court of Berlin Charlottenburg, Germany.

Part I: Privacy Policy

1. Data Controller

The data controller responsible for processing your personal data is Protocol Health GmbH. For any data protection inquiries, please contact us at the email address provided within the App or on our website.

2. Data We Collect

We collect the following categories of personal data when you use the App:

• Account & Identity Data: Name, email address, profile photo, and authentication credentials when you register via email/password, Sign in with Apple, or Google/social login.
• Health & Fitness Data: Training logs, workout performance, nutrition logs, body measurements, health metrics, recovery data, and any information you provide during your onboarding call or ongoing coaching interactions.
• Location Data: With your permission, we access your device's location to provide location-relevant features (e.g., nearby gyms or training facilities).
• Photos & Camera Data: With your permission, we access your camera and photo library for features such as progress photos or food logging.
• Device & Usage Data: Device type, operating system, app usage patterns, crash logs, and analytics data collected via third-party analytics providers.
• Payment Data: Transaction information related to in-app purchases, processed through Apple's App Store payment infrastructure. We do not store your credit card details directly.
• Communication Data: Messages and content exchanged through in-app coaching or support channels.

3. How We Use Your Data

We process your personal data for the following purposes:

• Providing and personalizing the Services, including training plans, nutrition plans, coaching, and health tracking
• Creating and managing your account and authenticating your identity
• Processing payments and managing subscriptions via in-app purchases
• Sending push notifications related to your training, coaching, or account
• Improving the App through analytics and performance monitoring
• Displaying advertisements through Google AdMob and Meta Audience Network
• Communicating with you regarding your account, service updates, or support
• Facilitating third-party services such as personal training, medical consultations, supplements, and meal preparation (see Section 5)
• Using non-sensitive testimonials for marketing purposes, subject to your consent (see Section 6)

4. Legal Basis for Processing (GDPR)

We rely on the following legal bases under the General Data Protection Regulation (GDPR):

• Contract Performance (Art. 6(1)(b) GDPR): Processing necessary to provide the Services you have subscribed to.
• Consent (Art. 6(1)(a) GDPR): For location access, camera/photos access, push notifications, testimonial use, and processing of health data (Art. 9(2)(a) GDPR).
• Legitimate Interests (Art. 6(1)(f) GDPR): For analytics, app improvement, fraud prevention, and advertising.
• Legal Obligation (Art. 6(1)(c) GDPR): Where required by applicable law, e.g., tax and accounting obligations.

5. Data Sharing with Third Parties

We share your personal data with the following categories of recipients:

• Personal Trainers & Coaches: If you are matched with or referred to a third-party personal trainer, we share relevant health, fitness, and scheduling data to enable them to provide their services.
• Healthcare Professionals: With your consent, we may share relevant health and fitness data with doctors or medical professionals involved in your care.
• Partner Services: We may share limited personal data with third-party partners who offer convenience services such as supplements, meal preparation, or fitness equipment. Data shared is limited to what is necessary to fulfill the relevant service.
• Google AdMob: We use Google AdMob to serve advertisements. AdMob may collect device identifiers and usage data for ad personalization. You can manage your ad preferences through your device settings.
• Meta Audience Network: We use Meta Audience Network to serve advertisements. Meta may collect device identifiers, usage data, and other information for ad personalization and measurement. You can manage your ad preferences through your device settings and your Meta account settings.
• Analytics Providers: We use third-party analytics tools to understand how the App is used and to improve performance. These providers receive anonymized or pseudonymized usage data.
• Apple: In-app purchase transactions are processed by Apple. Apple's own privacy policy governs their handling of payment data.

We do not sell your personal data. When we share data with third-party trainers, doctors, or partners, we do so only to the extent necessary to provide or facilitate the Services. All third-party recipients are contractually obligated to handle your data in accordance with applicable data protection laws.

6. Testimonials

By using the App, you consent to Protocol Health using non-sensitive testimonials (e.g., your name or initials and a general description of your experience) for marketing purposes, provided you have not expressed dissatisfaction in writing. You may withdraw this consent at any time with future effect by contacting us.

7. Data Retention

We retain your personal data for as long as your account is active and as needed to provide the Services. After account deletion or termination, we retain data only as required by applicable legal obligations (e.g., tax records) or legitimate business needs (e.g., resolving disputes). Analytics data is retained in anonymized form.

8. Your Rights Under GDPR

As a data subject under the GDPR, you have the following rights:

• Right of access to your personal data
• Right to rectification of inaccurate data
• Right to erasure ("right to be forgotten")
• Right to restriction of processing
• Right to data portability
• Right to object to processing based on legitimate interests
• Right to withdraw consent at any time without affecting the lawfulness of prior processing
• Right to lodge a complaint with a supervisory authority (in Germany: the Berlin Commissioner for Data Protection and Freedom of Information, or the relevant state authority)

To exercise any of these rights, please contact us using the contact information provided in the App.

9. International Data Transfers

Some of our third-party service providers (e.g., Google, Apple) may process data outside the European Economic Area (EEA). Where this occurs, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission or adequacy decisions.

10. Children's Privacy

The App is not intended for use by individuals under the age of 16. We do not knowingly collect personal data from children. If we become aware that a child under 16 has provided personal data, we will take steps to delete such data promptly.

11. Cookies & Tracking Technologies

The App may use cookies, SDKs, and similar tracking technologies for analytics and advertising purposes. You can manage tracking preferences through your device settings and the App Tracking Transparency prompt on iOS.

Part II: Terms of Service

1. Scope of Services

Protocol Health provides an online solution that may include individualized training plans, nutrition plans, educational content, asynchronous or synchronous coaching, feedback, and general guidance related to fitness, strength training, health, and lifestyle (the "Services").

The minimum service includes a personal onboarding call, a strength training protocol, a nutrition protocol, a recovery protocol, and daily customer support (Monday to Friday, response within 24 hours).

The Services may also include the mediation, recommendation, or coordination of third-party personal training services or physical gym usage.

No specific results are guaranteed. The Services do not constitute medical advice or treatment and do not replace consultation with a licensed physician or healthcare professional.

2. Account Registration

To use the App, you must create an account using one of the available sign-in methods (email/password, Sign in with Apple, or Google). You are responsible for maintaining the confidentiality of your login credentials and for all activities that occur under your account. You must provide accurate and complete information during registration.

3. In-Person Training & Third-Party Services

The Services are primarily provided online. In certain cases, Protocol Health may also provide or supervise in-person training sessions. Such training is delivered to the best of professional knowledge but remains subject to the inherent risks of physical activity.

Where you train in a physical gym or with a personal trainer other than Protocol Health (including trainers or gyms recommended or introduced by Protocol Health), such services are provided by independent third parties. Protocol Health is not liable for the actions, omissions, or quality of services provided by such third parties.

4. Assumption of Risk & Liability Waiver

You acknowledge that physical training involves inherent risks, including but not limited to the risk of injury. You voluntarily assume all risks associated with your participation in any physical activities recommended or facilitated through the App. To the maximum extent permitted by applicable German law, you release Protocol Health from liability for any injury, loss, or damage arising from your participation.

This waiver does not apply to liability for intentional misconduct or gross negligence, liability for injury to life, body, or health, or any other liability that cannot be excluded under mandatory German law.

5. Health Declaration

By using the App, you confirm that you are physically and mentally fit to participate in the fitness and training activities offered. You agree to seek appropriate medical clearance before beginning any new exercise or nutrition program, particularly if you have any pre-existing medical conditions.

6. Subscriptions, Fees & Payment

Access to the Services requires a paid subscription. Current pricing and subscription options are displayed within the App. Subscriptions are billed through in-app purchases via the Apple App Store.

• Minimum Commitment: Your initial subscription has a minimum commitment period as specified at the time of purchase.
• Renewal: After the initial commitment period, your subscription renews automatically on a quarterly basis until cancelled.
• Additional Services: Additional services (e.g., in-person training sessions, extra coaching calls) are subject to additional fees as communicated within the App. If Protocol Health processes orders for products (e.g., food, supplements, or equipment) on your behalf, the list price of the products will be charged with a mark-up as disclosed at the time of order. No additional services or products will be charged without prior notification.
• Refunds: Fees paid are generally non-refundable, except where mandatory statutory rights (including EU consumer withdrawal rights) apply. Missed or unused services do not entitle you to a refund. Cancellation of additional services can be requested at least 48 hours in advance of the scheduled time.
• Late Payment: In case of late payment, Protocol Health may suspend Services until full payment is received.

7. Vacation & Pausing the Service

You are entitled to pause your subscription for a maximum of two months per calendar year (e.g., for vacation), during which no fees shall be due. Pauses can be requested through the App. Protocol Health coaches may have reduced availability for up to 30 days per year, during which response times may be delayed.

8. Termination

After the initial commitment period, either party may terminate this agreement by providing at least 14 days' written notice before the end of the current billing period. You can cancel your subscription through the App or by contacting us directly.

Protocol Health reserves the right to suspend or terminate your account immediately if you violate these Terms, engage in fraudulent activity, or misuse the App.

9. In-App Purchases

The App offers in-app purchases for subscriptions and additional services. All in-app purchases are processed by Apple and are subject to Apple's terms and conditions. You are responsible for managing your own subscriptions through your Apple ID settings.

10. Intellectual Property

All content in the App, including but not limited to training plans, nutrition protocols, educational materials, software, design, and branding, is the intellectual property of Protocol Health GmbH or its licensors. You may not reproduce, distribute, modify, or create derivative works from any App content without prior written permission.

11. Confidentiality

All non-public information exchanged between you and Protocol Health in the course of the Services shall be treated as confidential. Neither party shall disclose confidential information to third parties without the other party's prior written consent, except as required by law or as necessary to provide the Services (e.g., sharing relevant data with your assigned trainer or healthcare professional).

12. User Conduct

You agree to use the App only for its intended purpose and in compliance with all applicable laws. You shall not:

• Use the App to harass, abuse, or harm other users, trainers, or staff
• Upload false, misleading, or inappropriate content
• Attempt to gain unauthorized access to the App or its systems
• Reverse-engineer, decompile, or otherwise attempt to extract the source code of the App
• Use the App for any commercial purpose not authorized by Protocol Health

13. Push Notifications

The App may send you push notifications related to your training schedule, coaching messages, account updates, and promotional content. You can manage your notification preferences in your device settings at any time.

14. Disclaimers

The App and Services are provided "as is" and "as available." To the maximum extent permitted by law, Protocol Health disclaims all warranties, express or implied, including warranties of merchantability, fitness for a particular purpose, and non-infringement.

Protocol Health does not guarantee uninterrupted or error-free operation of the App. Temporary service interruptions may occur for maintenance, updates, or reasons beyond our control.

15. Limitation of Liability

To the maximum extent permitted by applicable German law, Protocol Health's total liability to you for any claims arising out of or related to this agreement or the Services shall not exceed the total fees you have paid to Protocol Health in the twelve (12) months preceding the claim.

This limitation does not apply to liability for intentional misconduct, gross negligence, or injury to life, body, or health, or any other liability that cannot be limited under mandatory German law.

16. Changes to This Document

We may update this Privacy Policy & Terms of Service from time to time. We will notify you of material changes through the App or via email. Your continued use of the App after such changes constitutes acceptance of the updated terms. If you do not agree with any changes, you may terminate your account.

17. Governing Law & Dispute Resolution

This agreement is governed by the laws of the Federal Republic of Germany. If you are a consumer within the EU, you also benefit from any mandatory provisions of the law of your country of residence. Any disputes shall be subject to the jurisdiction of the courts of Berlin, Germany, unless mandatory consumer protection rules provide otherwise.

We are not obligated and generally not willing to participate in dispute resolution proceedings before a consumer arbitration board, but will assess participation on a case-by-case basis.

18. Severability

If any provision of this document is found to be invalid or unenforceable, the remaining provisions shall continue in full force and effect. The invalid provision shall be replaced with a valid provision that most closely achieves the intended economic and legal purpose.

19. Contact

If you have any questions about this Privacy Policy & Terms of Service, please contact:

Protocol Health GmbH
HRB 282672 B, Berlin Charlottenburg
Straßburger Str. 33, 10405 Berlin, Germany
info@protocol-health.ai

By creating an account and using the Protocol Health App, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy & Terms of Service in its entirety.