1. Overview
This Privacy Policy describes how Phorm Labs, Inc. (“Phorm,” “we,” “us,” or “our”) collects, uses, and shares information when you use the Phorm mobile application (the “App”), the website at phorm.app (the “Site”), and any related services (collectively, the “Services”).
By using the Services, you agree to the practices described in this Policy. If you do not agree, please do not use the Services.
2. Information We Collect
Account information
When you create an account, we collect your name, email address, and a securely hashed password (or, if you sign in with Apple, the unique identifier and email relay Apple provides). You may optionally provide your date of birth, biological sex, height, weight, training experience, and goals to personalize the App.
Video and pose data
Exercise form analysis is optional. Before you submit a recording, the App explains how it will be processed:
- The camera records video only; no audio is captured. Recordings are stored temporarily on your device and may identify you or other people visible in the frame.
- Choosing to analyze a recording sends the compressed video and exercise name over encrypted connections through our Cloudflare proxy to DeepInfra, which hosts the MiMo V2.6 Pro model and generates form feedback. We do not attach your name, email, or device identifier to this request.
- Our proxy does not persist the video, prompt, or AI feedback. DeepInfra states that it does not use these inputs or outputs to train models and applies zero data retention to this hosted inference service. We use synchronous inference without file storage, batch processing, or paid cache retention.
- The recording is deleted from your device after successful analysis or when you discard it or close the recorder. If analysis fails, it remains locally available for retry until you discard it or close the recorder.
DeepInfra's terms permit non-content operational metadata and retention required for legal compliance, fraud, security incidents, or abuse. They also permit transient in-memory processing and caching. See DeepInfra's Data Privacy documentation and Terms of Service for the scope and exceptions of its retention commitment.
Health and biometric data
With your explicit permission, Phorm reads the following from Apple HealthKit and connected wearable integrations (Apple Watch, Whoop, Oura, Garmin, Fitbit):
- Sleep duration, stages, and efficiency
- Heart rate variability (HRV)
- Resting heart rate (RHR)
- Active energy, workout history, and steps
- Body weight and body composition (if you log it)
This data is used to compute your Readiness Snapshot and to auto-regulate your daily training prescription. We never sell or share Health data with advertisers or data brokers, and Health data is treated as a special category subject to the additional safeguards described in Section 5.
Usage and device information
We automatically collect basic technical information when you use the Services: device model, OS version, App version, IP address (only at the request boundary; we do not log it persistently), crash reports, and aggregated, de-identified feature usage. We use this information to keep the App stable and improve performance.
Payments and subscriptions
Subscriptions to Phorm Pro are processed by Apple through the App Store. We do not receive or store your payment card information. We receive only a transaction identifier and the entitlement that lets us unlock Pro features for your account.
3. How We Use Information
- To provide the core service: to compute form scores, generate AI feedback, calculate Readiness, and prescribe and adjust your training.
- To operate your account: authenticate you, sync your training history across devices, and manage your subscription.
- To improve Phorm: we use aggregated, de-identified training and analytics data (never raw video, never identifiable biometrics) to improve our pose models, scoring, and the AI coaching engine. Exercise form videos and their AI feedback are not used to train models.
- To communicate with you: service announcements, security notices, billing receipts, and (only if you opt in) product updates.
- To keep the Services secure: to detect abuse, prevent fraud, enforce our Terms, and comply with legal obligations.
4. How We Share Information
Phorm does not sell your personal information. We share information only in the limited circumstances below:
- Service providers who process information on our behalf under strict confidentiality and data-protection agreements (e.g., cloud hosting, error monitoring, transactional email).
- Exercise form analysis: Cloudflare processes the request in transit, and DeepInfra processes the video and exercise name to return feedback, as described in the video section above.
- Wearable and Health integrations that you explicitly connect, only the scopes you grant and only for the purposes described above.
- Legal compliance and safety, when required by law, subpoena, or to protect the rights, property, or safety of Phorm, our users, or the public.
- Business transfers in connection with a merger, acquisition, or sale of assets, in which case we will notify you and your data will continue to be protected by a policy at least as protective as this one.
5. Special Treatment of Health Data
Consistent with Apple's App Store Review Guideline 5.1.1(iii) and the HealthKit Terms:
- We do not use Health, HealthKit, or Motion & Fitness data for advertising or any other use-based data mining purposes other than improving health, medical, and fitness management, or for the purpose of health research.
- We do not disclose Health data to third parties for advertising, marketing, or other use-based data mining purposes.
- We never write false or inaccurate data to HealthKit and we never store HealthKit data in iCloud.
6. Data Retention
We retain account data for as long as your account is active. Derived training history is retained until you delete the corresponding session or close your account.
Exercise form recordings are temporary: they are deleted locally after successful analysis, when discarded, or when you close the recorder. Our Cloudflare proxy does not persist the video, prompt, or feedback. DeepInfra's hosted inference retention commitment and exceptions are described above. Operational metadata, such as request times and error status codes, may be retained to operate the service.
When you close your account, we delete or anonymize your personal information within 30 days, except where retention is required by law (e.g., billing records).
7. Your Rights and Choices
Depending on where you live, you may have the right to access, correct, delete, or export your personal information, to object to or restrict processing, and to withdraw consent at any time. You can exercise most of these rights directly in the App:
- Access & export: Settings → Privacy → Export my data
- Delete a session or video: swipe on any session in your training journal
- Disconnect a wearable: Settings → Integrations
- Delete your account: Settings → Account → Delete account (this is permanent)
You may also email us at [email protected]. We respond to verified requests within 30 days.
8. Security
We implement industry-standard administrative, technical, and physical safeguards: TLS 1.3 in transit, AES-256 at rest, encrypted backups, principle-of-least-privilege access controls, regular third-party penetration testing, and immediate revocation of credentials on offboarding. No system is perfectly secure; we encourage you to use a strong, unique password and enable Sign in with Apple where possible.
9. Children
Phorm is not directed to children under 13 (or under 16 in the EEA and UK). We do not knowingly collect personal information from children. If you believe a child has provided us information, please contact [email protected] and we will delete it.
10. International Transfers
Phorm is based in the United States. If you access the Services from outside the United States, your information may be transferred to, stored, and processed in the United States and other countries. Where required, we rely on appropriate transfer mechanisms (e.g., Standard Contractual Clauses) for cross-border transfers.
11. California Privacy Rights
California residents have rights under the CCPA/CPRA, including the right to know what personal information we collect, the right to delete it, the right to correct inaccuracies, and the right to opt out of any “sale” or “sharing” of personal information. We do not sell or share personal information as those terms are defined under California law. To exercise your rights, email [email protected].
12. Changes to This Policy
We may update this Privacy Policy from time to time. If the changes are material, we will notify you in the App or by email at least 14 days before the changes take effect. The “Effective” date at the top reflects the most recent version.
13. Contact
Questions about this Policy or about your information? Reach us at:
Phorm Labs, Inc.
Attn: Privacy
548 Market St, PMB 60416
San Francisco, CA 94104
[email protected]