Privacy Policy.

01Introduction

This Privacy Policy describes how Apace Active LLC ("Apace Active," "we," "our," or "us"), a California limited liability company, collects, uses, and shares information about you when you use our mobile applications, including 75 Together, and our website at apaceactive.com (collectively, the "Services").

We built Apace Active because we wanted apps for couples doing fitness challenges together that didn't exist. We take the privacy of your fitness data — and your relationship — seriously, and this policy describes in plain language what we do with the information you share with us.

02What we collect

Information you provide directly

When you create an account or use the Services, you may provide:

• Account information: your email address, a chosen display name, and (optionally) a profile photo. If you sign in with Apple or Google, we receive a name and email from your Apple or Google account based on the permissions you grant.
• Partner pairing information: a 6-digit code (or QR code) that you share with your partner to pair your accounts in 75 Together. We use this code only to establish the pairing and discard it afterward.
• Daily challenge data: your daily progress on the 75 Hard requirements you choose to track — workout completion, water intake, reading status, diet adherence, and progress photos. This is the core data the app exists to track.
• Progress photos: if you choose to take or upload daily progress photos, those photos are stored in our backend and made available only to you and (if you choose) your paired partner. We do not analyze, share, or use your progress photos for any other purpose.
• Communications: if you email us at hello@apaceactive.com or support@apaceactive.com, we keep a record of that correspondence so we can respond and improve our services.

Information we collect automatically

When you use the Services, we and our service providers automatically collect:

• Device and technical information: device type, operating system version, app version, device identifiers (such as Apple's IDFV), language settings, and time zone. This information is used to deliver the app, troubleshoot issues, and understand which platforms our users are on.
• Usage information: how you use the app — which screens you visit, which features you use, how often you complete daily check-ins. We use this to improve the app and prioritize what to build next. This information is collected in aggregate and does not include the content of your check-ins.
• Crash and diagnostic information: if the app crashes or encounters an error, we receive a crash report through our error monitoring provider (Sentry). Crash reports include device state, the line of code that failed, and limited contextual information — but not your personal data, photos, or check-in content.
• Subscription and purchase information: if you subscribe to a paid plan, Apple processes your payment and tells us only that you have an active subscription (and which one). We do not receive your payment card information, billing address, or Apple Account credentials. Subscription status is delivered to us through RevenueCat, our subscription management provider.

Information we do NOT collect

To be explicit about what is not collected:

03How we use information

We use the information we collect to:

• Provide, operate, and maintain the Services — including syncing your daily progress between your devices and (if paired) with your partner's account.
• Send you transactional notifications about the app (challenge milestones, partner activity, account events) — only those you have opted into.
• Process subscription purchases and provide subscription benefits.
• Respond to your support requests and other communications.
• Analyze usage patterns to improve the app and decide what to build next.
• Detect, prevent, and respond to security incidents, fraud, and violations of our Terms of Service.
• Comply with legal obligations, including responding to valid legal process.

04How we share information

With your paired partner

The core feature of 75 Together is that two paired partners can see each other's daily progress in real time. When you pair with a partner, the following information becomes visible to that partner:

• Your display name and (if you set one) profile photo.
• Your daily check-in status — whether you have completed each of the 75 Hard requirements that day.
• Your current day count, streak, and overall completion progress.
• Optionally, the progress photos you choose to share with your partner. By default, photos are private to you; sharing with your partner is opt-in.

You can unpair from a partner at any time in the app's settings. Once unpaired, your future activity will not be visible to your former partner. Activity from the period when you were paired remains visible in your former partner's history of that period unless you delete your account.

With service providers

We use third-party service providers to operate the Services. These providers receive only the information necessary to perform their function and are contractually required to protect your information. The providers we currently use are:

• Google Firebase (provided by Google LLC) — backend infrastructure, account authentication, real-time data synchronization, push notifications, and basic analytics. Firebase's privacy practices are described at firebase.google.com/support/privacy.
• RevenueCat (provided by RevenueCat, Inc.) — subscription management. RevenueCat receives a device identifier and your subscription status. Their privacy policy is at revenuecat.com/privacy.
• Sentry (provided by Functional Software, Inc., dba Sentry) — crash and error reporting. Their privacy policy is at sentry.io/privacy.
• Apple — payment processing for App Store purchases, Sign in with Apple authentication, and the App Store itself. Apple's privacy policy is at apple.com/legal/privacy.

We do not sell your personal information to anyone, and we do not share your information with third parties for their own marketing purposes.

For legal reasons

We may disclose information when we have a good-faith belief that doing so is necessary to:

• Comply with a valid legal process (subpoena, court order, government request).
• Enforce our Terms of Service or investigate violations.
• Protect the rights, safety, or property of Apace Active, our users, or the public.

In a business transfer

If Apace Active is acquired, merged, or sells substantially all of its assets, your information may be transferred to the acquiring entity. We will notify you (by email or an in-app notice) before your information becomes subject to a different privacy policy.

05Health and fitness data

Apace Active treats the daily progress data you log in our apps as health and fitness information, even though we are not a medical device or healthcare provider. Specifically:

• We never use, sell, or disclose your fitness data — including workout completion, weight, photos, and other 75 Hard tracking — for advertising, marketing, or any purpose other than providing the Services to you and your paired partner.
• We do not share your fitness data with data brokers, ad networks, or marketing partners.
• Personal health information is not stored in iCloud. Daily progress data is stored in our backend (Firebase), encrypted in transit and at rest.
• Apace Active is a fitness tracking tool. It is not a medical device, and the information it provides is not medical advice. Consult your physician before starting any fitness program, including the 75 Hard challenge.

06Data retention

We retain your information for as long as your account is active. When you delete your account (described in Section 7 below), we delete your information from our active systems within 30 days, except where we are required to retain certain information for legal, tax, or fraud-prevention reasons.

Crash reports and aggregated analytics data may be retained beyond account deletion, but in a form that is not associated with your account or personal identity.

Your paired partner's view of historical activity from when you were paired may persist in their account history unless you specifically request deletion of that data through us.

07Your rights

Account deletion (all users)

You can delete your account at any time from within the app. Account deletion will:

• Remove your account, profile information, and all daily progress data from our active systems.
• Delete any progress photos you have uploaded.
• Disconnect any active partner pairing.
• Cancel your access to paid subscription benefits (subscription itself is managed by Apple — see below).

If you have trouble deleting your account through the app, you can email hello@apaceactive.com and we will process the deletion manually within 30 days.

Access and correction

Most of the information we have about you is visible directly within the app — your account info, daily check-ins, photos, and partner relationship. You can edit most of it in app settings. If you would like a complete export of your data, email hello@apaceactive.com.

California residents

If you are a California resident, the California Consumer Privacy Act ("CCPA") may give you additional rights, including:

• The right to know what personal information we have collected about you.
• The right to request deletion of your personal information.
• The right to correct inaccurate personal information.
• The right to limit the use and disclosure of sensitive personal information.
• The right not to be discriminated against for exercising your privacy rights.

We do not sell or share your personal information (as those terms are defined under the CCPA), and we do not engage in cross-context behavioral advertising. We have not sold or shared personal information in the previous 12 months.

To exercise your California rights, email hello@apaceactive.com with the subject line "California Privacy Request." We may need to verify your identity before processing your request.

European Economic Area, United Kingdom, and Switzerland residents

If you are in the EEA, UK, or Switzerland, you have rights under the General Data Protection Regulation ("GDPR") or equivalent local law, including the right to access, correct, delete, restrict, or object to our processing of your personal data, and the right to data portability.

Our legal basis for processing your information is generally:

• Performance of a contract: to provide the Services you have signed up for.
• Legitimate interests: to operate, secure, and improve the Services.
• Consent: for optional features such as push notifications.
• Legal obligation: to comply with applicable law.

To exercise your GDPR rights, email hello@apaceactive.com. You also have the right to lodge a complaint with your local data protection authority.

08Children's privacy

The Services are not directed at children under 13 (or under 16 in the European Economic Area). We do not knowingly collect personal information from children under these ages. If we learn that we have collected information from a child under the applicable minimum age, we will delete that information promptly.

If you are a parent or guardian and believe we may have collected information from your child, please contact us at hello@apaceactive.com.

09Data security

We implement reasonable technical and organizational measures designed to protect your information, including:

• Encryption in transit (TLS) for all communications between the app and our backend.
• Encryption at rest for stored data, using the encryption built into Firebase and Firebase Storage.
• Authentication — your account is protected by Sign in with Apple, Sign in with Google, or a strong password.
• Limited internal access to personal data — only the small number of people who operate Apace Active have access, and only when necessary.

No system is perfectly secure. While we work to protect your information, we cannot guarantee absolute security. If you become aware of a security issue, please email hello@apaceactive.com so we can investigate.

10International data transfers

Apace Active is based in the United States. If you use the Services from outside the United States, your information will be transferred to and processed in the United States, where data protection laws may differ from those in your country. By using the Services, you consent to this transfer.

11Changes to this policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email and/or by an in-app notice before the changes take effect. The "Effective" date at the top of this policy reflects the most recent update. Your continued use of the Services after the effective date constitutes acceptance of the updated policy.

12Contact us

If you have questions about this Privacy Policy or our privacy practices, please contact us:

• Apace Active LLC
• Email: hello@apaceactive.com
• Website: apaceactive.com
• Mailing address: [TO BE COMPLETED with Northwest Registered Agent address from LLC-1]

This Privacy Policy was last updated on [TO BE COMPLETED]. Apace Active LLC is a California limited liability company.