Privacy policy

KAI Swiss is a brand operated by KAI Technologies SA.

This policy explains which personal data we process when you use the kaiswiss.com website and the KAI Swiss app, why we process it, who we share it with and what your rights are. We wrote it to match what the app actually does.

1. CONTROLLER

KAI Technologies SA Public limited company under Swiss law UID: CHE-133.837.956 La Chotte 1, 2043 Boudevilliers, Switzerland General contact: [email protected] Data protection: [email protected]

2. SCOPE

This policy applies to processing carried out in connection with:

– the kaiswiss.com website;

– the kaiswiss.app web app and the KAI Swiss mobile apps for iOS and Android;

– the related services, features and subscriptions

(the “Services”).

3. LEGAL FRAMEWORK

Processing is carried out in accordance with the Swiss Federal Act on Data Protection (FADP) and its Ordinance (DPO), and with Regulation (EU) 2016/679 (GDPR) where it applies, in particular to users located in the European Union or the European Economic Area (EEA).

4. PRINCIPLES

We process personal data lawfully, fairly and transparently, for specified purposes, limited to what is necessary, keeping it accurate, storing it no longer than needed and keeping it secure.

We do not sell your data.

5. DATA WE PROCESS

Depending on the features you use, we process the following categories:

5.1 Account

– email address, first and last name, profile photo (optional);

– sign-in method (email and password, Apple or Google);

– language, time zone and account settings;

– subscription status and history.

5.2 Profile and goals

– age, sex, height, current weight, starting weight and target weight;

– goals, fitness level, availability and lifestyle habits (sleep, steps);

– dietary preferences, foods you avoid or dislike.

5.3 Health-related data

Some data is sensitive data within the meaning of the FADP and the GDPR (see Article 6):

– food allergies, injuries and, if you choose to provide them, current medications;

– weight, body measurements, body composition and progress photos;

– videos you send for movement analysis;

– if you connect Apple Health or Health Connect: steps, sleep (duration and stages), workouts, heart rate, resting heart rate, heart rate variability and, on iOS, GPS routes of workouts. The app reads this data; it does not write any data to Apple Health or Health Connect;

– training data: sessions, loads, perceived exertion, notes.

5.4 Nutrition

– meal photos, logged or scanned meals, estimated nutritional values;

– recipes, shopping lists, hydration.

5.5 Conversations with the coach

– text messages, voice messages and images you send to the coach;

– information the coach remembers to personalise its support (“coach memory”), which may include information you share about your health or personal life.

5.6 Location and outdoor activities

– GPS position during an outdoor activity you have started, recorded tracks and routes, favourite places;

– location is only collected once you start an activity, and never in the background outside an activity.

5.7 Social features

– friends list, invitations, challenges, encouragements and content you choose to share (workouts, meals, recipes, shopping lists);

– if you allow access to your contacts to find friends: phone numbers are turned into fingerprints (hashes) on your device and only these fingerprints are sent to us. Your address book is not copied to our servers.

5.8 Usage and technical data

– app usage events (features used, screens, interactions);

– device type, operating system, app version, language, IP address, browser;

– technical notification identifiers, error and security logs;

– where your sign-up came from (campaign, link or source through which you found us).

5.9 Payment

Payments are processed by Apple, Google or Stripe. We receive the subscription status, amount and currency, but never your full card details.

5.10 kaiswiss.com website

– server logs (IP address, browser, pages requested);

– your browser language, used to redirect you to the right language version without being stored;

– clicks on our download links (/app, /go), with the source of the visit (UTM parameters);

– if you fill in the “Insurers & companies” form: name, organisation, email address, type of organisation and message.

6. HEALTH DATA

KAI Swiss is a non-medical coaching service. It does not diagnose, does not offer treatment and does not replace a health professional.

The data listed in Article 5.3 is nevertheless sensitive data. We process it:

– only if you choose to provide it: it is optional, and most features remain available without it;

– on the basis of your explicit consent, which you give by entering it in the app or by granting access to Apple Health or Health Connect;

– solely to provide and personalise the coaching.

You can withdraw your consent at any time: by removing this information from your profile, by revoking access in the Apple Health or Health Connect settings, or by deleting your account.

Health data is never used for advertising, is not shared with Meta or any other advertising network, and is not disclosed to insurers, employers or third parties for commercial purposes. Data from Apple Health and Health Connect is used in accordance with Apple’s and Google’s rules.

7. PURPOSES

We process your data to:

– create and manage your account and subscription;

– provide the coaching: nutrition and training plans, meal and movement analysis, reviews, coach replies;

– run the social features you enable;

– send you service-related notifications and emails;

– provide support and follow up on your requests;

– measure use of the Services, fix errors and improve the app;

– measure the effectiveness of our advertising campaigns (Article 11);

– ensure security and prevent fraud and abuse;

– comply with our legal obligations, in particular accounting obligations.

8. LEGAL BASES

Where the GDPR applies, our processing is based on:

– performance of the contract (Art. 6(1)(b) GDPR): account, subscription, coaching, social features;

– your explicit consent (Art. 9(2)(a) GDPR): health data;

– your consent (Art. 6(1)(a) GDPR): access to contacts, location, camera, microphone and notifications, which you grant through your device permissions;

– our legitimate interests (Art. 6(1)(f) GDPR): security, bug fixing, app analytics, measurement of our advertising campaigns, improvement of the Services;

– our legal obligations (Art. 6(1)(c) GDPR): retention of accounting records, responses to authorities.

Under Swiss law, this processing is justified by compliance with the principles of the FADP and, where required by law, by your explicit consent.

9. ARTIFICIAL INTELLIGENCE

The KAI coach relies on artificial intelligence models provided by specialised providers. To generate a reply, a plan or an analysis, we send them, through our servers, the information needed for the request: your message, the relevant parts of your profile (for example goals, weight, allergies, injuries), the photo of a meal or the video of a movement.

These providers are accessed through endpoints located in Switzerland or the European Union.

Generated replies may be inaccurate. They are not decisions with legal effects on you, nor medical advice (see Article 16).

When the coach detects a situation that deserves a person’s attention (for example signs of distress, a health concern or a technical problem), a summary and an excerpt of the conversation, together with your name and email address, are sent to the KAI team. Only authorised staff have access to them, in order to follow up and keep users safe.

10. RECIPIENTS AND SERVICE PROVIDERS

We use the following providers, which process data on our behalf and according to our instructions (processors), or as independent controllers where indicated:

– Supabase: database, authentication and file storage — European Union (France);

– Hostinger: hosting of the website, the web app and our AI orchestration server — European Union;

– Cloudflare: delivery and protection of the website — global network, including the United States;

– AI model providers: generating replies and analyses (Article 9) — Switzerland and the European Union;

– Mixpanel: app analytics — European Union (parent company in the United States);

– Sentry: technical error monitoring — European Union (parent company in the United States);

– OneSignal: push notifications — United States;

– Resend: service emails and internal alerts — United States;

– RevenueCat: management of subscriptions purchased in the mobile apps — United States;

– Stripe: web payments — Ireland and United States (independent controller for certain legal obligations);

– Apple and Google: app stores, in-app payments, Sign in with Apple or Google, Apple Health and Health Connect — United States (independent controllers);

– Meta Platforms: measurement of our advertising campaigns (Article 11) — Ireland and United States;

– Mapbox (United States), openrouteservice / HeiGIT (Germany), Open-Meteo (Switzerland and European Union) and swisstopo (Switzerland): maps, routes and weather for outdoor activities, based on geographic coordinates only.

Your data may also be disclosed:

– to friends you are connected with, according to your sharing settings. By default, your friends see your goal, consistency and workouts; your weight, photos and nutrition are only shared if you turn this on. You can change these settings at any time in the app;

– to authorities, where required by law;

– to an acquirer or successor in the event of a merger, sale or restructuring, subject to the same safeguards.

Authorised staff of KAI Technologies SA only access user data where necessary for support, security or the proper functioning of the Services.

11. ADVERTISING AND ANALYTICS

11.1 Campaign measurement (Meta)

To measure the effectiveness of our ads on Facebook and Instagram, we send Meta certain events: account creation, tutorial completion and subscription purchase, with its amount and currency. These events are accompanied by your email address, name, sex and an internal identifier in hashed (unreadable) form, as well as your IP address, device information and Meta technical identifiers. On Android and on the web, the device advertising identifier or a Meta cookie may be used.

No health, coaching or conversation data is sent to Meta.

You can object to this at any time by writing to [email protected]. You can also limit ad personalisation in your device settings and your Meta account.

11.2 App analytics (Mixpanel)

We measure how the app is used (features used, user journeys, subscriptions) in order to improve it. These statistics are linked to your account identifier and may include your email address and name; they do not contain the content of your conversations with the coach. You can object by writing to [email protected].

12. INTERNATIONAL TRANSFERS

Your data is mainly hosted in the European Union. However, some providers listed in Article 10 are located in the United States or may access data from there.

Depending on the provider, these transfers are covered by certification under the Swiss-U.S. Data Privacy Framework and the EU-U.S. Data Privacy Framework, or by the European Commission’s standard contractual clauses, recognised by the Federal Data Protection and Information Commissioner (FDPIC) and supplemented with the adjustments required by Swiss law.

You can obtain information about these safeguards by writing to [email protected].

13. RETENTION

– Account, profile, coaching, health and nutrition data, conversations, photos and videos: for as long as your account exists. When you delete your account, this data is erased from our active systems; technical backups are overwritten according to their rotation cycle.

– Outdoor activities: GPS tracks kept until you delete the activity or your account; GPS data from incomplete uploads erased after 30 days.

– Payment and billing data: 10 years, in accordance with Swiss accounting obligations (Art. 958f CO).

– Support requests and the “Insurers & companies” form: up to 24 months after the last exchange.

– Usage statistics and technical logs: a limited period, proportionate to their purpose.

Data held by providers acting as independent controllers (Apple, Google, Stripe, Meta) is retained according to their own policies.

14. SECURITY

We take appropriate technical and organisational measures to protect your data against loss, unauthorised access, disclosure and alteration, in particular:

– encryption of communications (HTTPS/TLS);

– database-level access control rules, so that each user can only access their own data;

– private storage of progress photos, movement videos and images sent to the coach;

– internal access limited to authorised staff, logging and incident management.

As no system is infallible, absolute security cannot be guaranteed. If a data breach is likely to result in a high risk to you, we will inform you and the competent authority, as required by law.

15. YOUR RIGHTS

Under the FADP and, where applicable, the GDPR, you have the right to:

– access your data and obtain a copy;

– have it corrected;

– have it erased: you can delete your account directly in the app (Settings → Delete my account);

– receive your data in a structured, commonly used format (portability);

– restrict or object to certain processing, in particular advertising measurement and analytics;

– withdraw your consent at any time, without affecting the lawfulness of processing already carried out.

To exercise these rights, write to [email protected] from the email address linked to your account. We reply within 30 days.

You may also lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC, www.edoeb.admin.ch) or, if you live in the European Union, with the data protection authority of your country.

Deleting the app does not delete your account or cancel your subscription.

16. AUTOMATED DECISIONS

The coach’s recommendations are generated automatically, but they are not automated individual decisions producing legal effects concerning you or similarly significantly affecting you. You remain free to follow them or not.

17. COOKIES AND SIMILAR TECHNOLOGIES

– kaiswiss.com website: the website sets no cookies and uses no analytics or advertising tools. Fonts are hosted on our own servers.

– kaiswiss.app web app: we use your browser’s local storage to keep you signed in and remember your preferences, and the Meta pixel for the advertising measurement described in Article 11.

– Mobile apps: we use the software development kits of Meta, Mixpanel, OneSignal, Sentry and RevenueCat for the purposes described in this policy. On iOS, we do not ask for tracking permission (App Tracking Transparency) and therefore do not access your device’s advertising identifier.

18. MINORS

The Services are reserved for people aged 18 or over. We do not knowingly collect data about minors. If we learn that an account belongs to a minor, we delete it.

19. LINKS TO THIRD-PARTY SERVICES

The Services may contain links to third-party websites or services (for example social networks or press articles). These third parties apply their own privacy policies, for which we are not responsible.

20. CHANGES

We may change this policy to reflect changes to the Services or to the law. The version in force is the one published on this page, with its update date. If we make significant changes, we will let you know in the app or by email.

21. LANGUAGE AND GOVERNING LAW

This policy is available in French, German and English. In the event of any discrepancy between the versions, the French version prevails.

It is governed by Swiss law, subject to the mandatory provisions of the law of your country of residence.