Privacy Policy

Last updated: August 31, 2026

PHYSICALLY LLC (“PHYSICALLY,” “we,” “us,” or “our”) takes your privacy seriously. Please read this Privacy Policy carefully. It explains who we are, what personal information we collect, why we collect it, how we use and protect it, who we share it with, and your rights regarding your information.

This Privacy Policy applies to your use of the PHYSICALLY mobile application (the “App”). By creating an account or using the App, you agree to the collection and use of your information as described in this Privacy Policy.

The App is currently available in the United States only. We are responsible for the personal information we collect and use in connection with the App, and we handle that information in accordance with applicable U.S. law. If we expand to additional jurisdictions in the future, we will update this Privacy Policy accordingly.

Key Terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our.

PHYSICALLY LLC

Personal information.

Any information relating to an identified or identifiable individual

Special category personal information

• Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership
• Genetic and biometric data
• Data concerning health, sex life, or sexual orientation

Personal Information We Collect About You

• Account and registration information, including your email address, password, and account credentials;
• Profile and onboarding information, including your date of birth or age, gender, height, weight, fitness goals, experience level, equipment preferences, and weight-related goals;
• Health and fitness activity data, including heart-rate information, activity data, and related biometric metrics obtained from Apple HealthKit or Google Health APIs when you authorize that connection;
• Exercise and workout data, including your workout history, exercise selections, sets, repetitions, weights, estimated one-repetition maximum values, and program progress;
• Rehabilitation and symptom data, including symptom locations you select on the body map, baseline assessment responses, symptom ratings, range-of-motion information, and rehabilitation program progress;
• Subscription and transaction data, including your subscription tier, subscription status, and App Store or Google Play transaction identifiers. PHYSICALLY LLC does not receive or store your payment card or financial account information; all payment processing is handled exclusively by the Apple App Store or Google Play;
• Device and technical information, including device identifiers, operating system, crash reports, diagnostic data, and app-usage analytics collected to operate, improve, and secure the App;
• Communications and support records, including messages you send to us for customer support, account-deletion requests, and related correspondence;

Some of the information listed above is required to create your account and provide the App’s core features. If you do not provide required information, you may not be able to create an account or access certain features.

How Your Personal Information is Collected

We collect personal information primarily in the following ways:

• Directly from you, when you create an account, complete the onboarding process, enter workout or health data, respond to in-app prompts, or contact us for support;
• From Apple HealthKit or Google Health APIs, when you authorize the App to access your health and activity data from those platforms. That access is subject to your authorization and the applicable Apple or Google privacy policies;
• Automatically, through device and diagnostic systems that collect technical and usage information as you use the App; and
• From third-party analytics, attribution, lifecycle communication, and advertising service providers that may be integrated into the App. We describe these integrations below under Third-Party Services and Analytics.

How and Why We Use Your Personal Information

We use the personal information we collect for the following purposes:

• To create and maintain your account and provide you with access to the App’s features;
• To personalize your fitness, workout, and rehabilitation experience based on the information you provide during onboarding and in-app;
• To support the HART cardiovascular activity feature by processing heart-rate and activity data obtained from Apple HealthKit or Google Health APIs when you authorize that connection;
• To support the intermittent-fasting tracking function by processing timer and fasting information you enter directly into the App. The intermittent-fasting function does not use data obtained from Apple HealthKit or Google Health APIs;
• To process, validate, and manage your subscription through the Apple App Store or Google Play;
• To send you in-app notifications about your workouts, programs, account, and app updates;
• To improve, maintain, and secure the App through diagnostic data, crash reports, and usage analytics;
• To respond to your support requests and communications; and
• To comply with applicable law and legal obligations.

Apple HealthKit and Health Data

If you choose to connect the App to Apple HealthKit, the App will request permission to read heart-rate and activity information from Apple HealthKit. We use that information solely to support the in-app features you have enabled, including the HART cardiovascular activity feature.

We do not use Apple HealthKit data for advertising, marketing, or any purpose unrelated to providing the App’s health and fitness features to you. We do not share Apple HealthKit data with third parties except as required to provide those features or as required by law.

You may revoke the App’s access to Apple HealthKit at any time through your device settings.

Third-Party Services and Analytics

The App may integrate, or in the future may integrate, third-party services for analytics, attribution, advertising measurement, lifecycle communications, push notifications, crash reporting, and app-infrastructure purposes.

These may include, without limitation, services in the following categories: product analytics and event tracking; mobile attribution and campaign measurement; advertising platforms (such as Meta/Facebook, Google Ads, and Apple Search Ads); lifecycle and engagement tools (such as push notification and in-app messaging services); and crash reporting and performance monitoring tools.

When such integrations are in place, those third-party services may receive certain App usage data, device identifiers, and other information described in this Privacy Policy in order to perform their functions. We do not authorize those services to use your information for any purpose other than providing their services to us.

We currently do not sell your personal information to any third party, and we do not share your personal information with third parties for their own independent marketing or advertising purposes.

You have the right to opt out of receiving promotional communications from us at any time.

The App currently uses in-app notifications only. You may manage notification preferences through your device’s notification settings.

Who We Share Your Personal Information With

When necessary, we will share personal information with:

• Third parties we use to help deliver our services to you, e.g., payment service providers.
• Third parties we use to help us run our business, e.g., marketing agencies, attorneys, auditors, or website hosts;
• Third parties approved by you, e.g., social media sites you choose to link your account to or third party payment providers;

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. 

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We Do Not Sell or Disclose Personal Information.

We do NOT sell any personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This includes:

• Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
• Characteristics of protected classifications under applicable law;
• Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
• Biometric information;
• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
• Geolocation data;
• Audio, electronic, visual, thermal, olfactory, or similar information;
• Professional or employment-related information;
• Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Where Your Personal Information is Held

Information may be held at our offices and those of our service providers, representatives, and agents as described above (see above: “Who We Share Your Personal Information With”).

PHYSICALLY LLC’s servers are located in the United States. Your information is processed and stored in the United States.

How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information:

• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly;
• To keep records required by law.

We will not retain your personal information for longer than necessary. 

Data Retention

We retain your personal information for as long as your account is active or as needed to provide services to you. Currently, user data is retained indefinitely unless you request deletion.

If you request deletion of your account and personal information, you may do so through the profile settings screen within the App by selecting the account-deletion option.

We will process your deletion request in accordance with applicable law. Certain information may be retained after deletion where required by law or to complete pending transactions, resolve disputes, or enforce our agreements.

Security

We take reasonable and appropriate measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction.

Our security practices include penetration testing and security scans approximately every 30 days, and rotation of all logins and access keys approximately every 90 days. Access to personal information is limited to personnel and service providers with a legitimate need.

We maintain procedures to address suspected data security incidents and will notify you and any applicable regulator of a security breach as required by law.

Do Not Track

To exercise any of your rights under applicable state law, please contact us at the address below. We will respond to verifiable requests within the time period required by applicable law.

The App is a mobile application and does not respond to browser-based ’Do Not Track’ signals. If we add a web-based component to the service in the future, we will update this Privacy Policy to address Do Not Track practices applicable to that component.

Keeping Your Personal Information Secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way.

We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Links to Third Party Websites

We do offer links to other websites. When you click on links to other websites, we encourage you to read their privacy policies. Their standards may differ from ours.

How to Complain

Residents of certain states have additional or heightened protections with respect to consumer health data. These include, among others, Washington (My Health My Data Act), Nevada (SB 370), California (CCPA/CPRA), Connecticut, Colorado, Oregon, and Maryland.

If you are a resident of any of these states, or any other state that provides specific rights with respect to consumer health data, the rights described in this section, including the right to consent, access, correction, deletion, and withdrawal of consent apply to you.

Washington residents have the additional right to receive a list of all third parties with whom we have shared or sold their consumer health data.

To exercise any of these rights, contact us at privacy@physically.co.

Consumer Health Data

The App collects and processes health-related information, including biometric data, symptom data, fitness and activity data, and health metrics obtained from Apple HealthKit or Google Health APIs, that may constitute 'consumer health data' under applicable state law, including laws in Washington, Nevada, California, Connecticut, Colorado, Oregon, Maryland, and other states that regulate consumer health data.

This section describes our specific practices with respect to that information.

Categories of Consumer Health Data We Collect

• Heart-rate, activity, and biometric data obtained from Apple HealthKit or Google Health APIs when you authorize that connection, used solely to support the HART cardiovascular activity feature;
• Workout history, exercise selections, sets, repetitions, weights, and estimated one-repetition maximum values;
• Symptom locations, baseline assessment responses, symptom ratings, and rehabilitation program progress;
• Calculated metrics generated by the App, including HART heart-rate zones and scores, Strength Balance assessments, Muscle Readiness scores, readiness assessments, and estimated one-repetition maximum values; and
• Intermittent-fasting timer and fasting information you enter directly into the App.

How We Use Consumer Health Data

We use consumer health data only to provide the App’s features and services directly to you, as described in this Privacy Policy.

We do not sell consumer health data. We do not share consumer health data with third parties for their own independent marketing or advertising purposes.

Where third-party analytics or infrastructure providers receive any health-related data as necessary to deliver their services to us, we contractually restrict their use of that data to providing those services.

Your Rights Regarding Consumer Health Data

Depending on your state of residence, you may have the following rights with respect to your consumer health data:

• The right to confirm whether we are collecting, sharing, or selling your consumer health data;
• The right to access a copy of your consumer health data;
• The right to request correction of inaccurate consumer health data;
• The right to request deletion of your consumer health data;
• The right to withdraw consent to our collection or sharing of your consumer health data;
• The right not to be discriminated against for exercising any of these rights.

To exercise any of these rights, please contact us at privacy@physically.co.

We will respond to verifiable requests within the time period required by applicable law, and we may request verification of your identity before processing your request.

Consent to Health Data Collection

By authorizing the App to connect to Apple HealthKit or Google Health APIs, you consent to our collection and processing of your health and biometric data from those sources for the purposes described in this Privacy Policy.

You may revoke this authorization at any time through your device’s settings. If you revoke authorization, features that rely on connected health data, including the HART feature, will no longer function.

State-Specific Privacy Rights

Residents of certain states have additional or heightened protections with respect to consumer health data. These include, among others, Washington (My Health My Data Act), Nevada (SB 370), California (CCPA/CPRA), Connecticut, Colorado, Oregon, and Maryland.

If you are a resident of any of these states, or any other state that provides specific rights with respect to consumer health data, the rights described in this section, including the right to consent, access, correction, deletion, and withdrawal of consent, apply to you.

Washington residents have the additional right to receive a list of all third parties with whom we have shared or sold their consumer health data.

To exercise any of these rights, contact us at privacy@physically.co.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you through the App and, where required, ask you to review and accept the updated policy before continuing to use the App.

The date of the most recent update will appear at the top of this page.

How to Contact Us

Please contact us at privacy@physically.co if you have any questions about this Privacy Policy or the information we hold about you.

PHYSICALLY LLC

10710 Ravenna Way, Unit 104

Fort Myers, FL 33913