Privacy Policy

Smuga is an app and the website smuga.app for trainers and their clients. For now Smuga is run by its developer, Yaroslav Kulpan, as a private individual ("Smuga", "we"). He decides why and how your data is processed, so he is its controller.

For anything about your data, consents or this policy, write to support@smugaspace.com. When a sole proprietorship or company is registered, we will update this section and let you know.

This policy covers the Smuga app for iOS and Android, the website smuga.app, emails to our address and the support bot in Telegram. It describes the data of clients, trainers, people a trainer invites, website visitors and people who join the beta waitlist.

The trainer you work with is responsible for how they use data you give them outside Smuga (for example, in their own notes or messengers). What a trainer may do with your data in Smuga is set out in the Terms of Service.

Only what Smuga needs to work. Here is the full list by role.

• Account: email, name, app language, time zone, how you sign in (password, Google, Apple or another provider), and your phone number if you add it. We store your password only as a hash.
• Client profile: name, gender, date of birth, city, profile photo, fitness level, goals, preferred training format and place, budget, preferences for a trainer.
• Trainer profile: name, date of birth, gender, photo, bio, experience, specializations, social links, training photos, intro video, city, gyms, prices and packages, rating. The profile and intro video are public: anyone can see them in the catalog and on the website.
• Trainer verification: a short video and photo of your face (see "Health data and consents"), scans of certificates and diplomas. We don't ask for identity documents.
• Health (only with a separate consent): height, weight, measurements, progress photos, check-ins, the questionnaire (injuries, chronic conditions, contraindications), nutrition and water, workouts from Apple Health or Health Connect.
• Training and bookings: programs, completed workouts, sets and personal records, streaks, bookings, packages, payments the trainer marked as received.
• Chat: messages, photo attachments, reactions, blocks and reports.
• Reviews: text and rating.
• Invites: the name, email or phone of the person a trainer invites, if the trainer enters them.
• Device and technical data: the push notification token, IP address and browser or device details in sessions, server logs and consent records, app crash reports, views of trainer profiles (the viewer's IP and browser).
• Google Calendar, if you connect it: we create events in it with the client's name, the service, time, place and payment status.
• Beta waitlist: email (the one in your Apple ID or Google account, so we can add you as a tester), name, role, city, specialization or goal, language.
• Support in Telegram: your Telegram id, name, role and language; we forward the messages themselves to the support team and don't store them separately.
• The form on the Contact page: name, email, the message and the site's language. We reply by email to that address.

Each kind of processing has a legal basis under the Law of Ukraine "On Personal Data Protection" and the GDPR. Here they are.

Health data is a special category, so it only works with a separate explicit consent. The box stays unticked until you tick it yourself. Without this consent Smuga doesn't store your weight, measurements, health questionnaire or nutrition.

If you withdraw the storage consent, every trainer's access to your health data closes and the data is frozen. We delete it after 30 days unless you agree again. Progress photos are a separate consent.

A trainer's face check is biometric data. We ask for a separate consent before recording. Only Smuga moderators see the video and photo, to match them with the profile. We don't use them for anything else and delete them 30 days after the decision.

Every consent is stored with the version and a fingerprint (hash) of the exact text you saw, the time, language, IP address, device and sign-in method. The consent log is protected against unnoticed changes. When you give a trainer access, we email you a copy of the consent with a PDF.

You can withdraw any consent in the app settings ("My trainers", "Health & plan", "Privacy") or by writing to support@smugaspace.com. Withdrawing doesn't undo what was done before it.

A trainer sees only what they need to work with you, and only while you are connected.

• Always: your name and photo, the goals in your profile, bookings, packages, payments, programs and workouts done with them, your chat with them.
• Only with your consent to health access: weight, measurements, the health questionnaire, nutrition, workouts from Apple Health or Health Connect.
• Only with a separate photo consent: progress photos, except the ones you marked private.
• After you stop training together: only who you were to them, and payments.

We use AI in four places. None of them makes decisions about you with legal effects.

• A client summary for the trainer (OpenAI): gender, age band, goals, level, number of workouts, exercises, records and streak. No name, contacts or health data.
• Trainer matching (OpenAI): goals, level, city, schedule and preferences become a numeric description (an embedding) used for search. We don't add health data from the questionnaire or tracking to it.
• A trainer's bio (OpenAI): what the trainer entered, to suggest a text. The trainer decides whether to use it.
• Moderation (OpenAI): review texts, a trainer's profile text, photo and up to three training photos. Public photos (avatars, a trainer's photos and exercise images) are checked automatically for nudity, violence and self-harm before they are published; we never send private photos (progress, documents, chat) for this check. AI does the first check; a human moderator decides a profile's first publication, unclear cases and every review.

We don't sell your data and we show no ads. Data goes only to services Smuga can't work without, and only as much as they need.

Some services run in the USA. We transfer data to them under their data processing agreements with the Standard Contractual Clauses approved by the European Commission, or under the EU–US Data Privacy Framework where the service has joined it.

We don't send health data from the questionnaire or tracking to AI services.

While your account exists, as long as Smuga needs it to work. Specific periods:

• Account: deleted 30 days after you ask (you can restore it until then). History shared with other people (chats, workouts the trainer ran, payments, reviews) stays, but shows "Deleted account" instead of you.
• Minimal proof of consents after an account is deleted: 3 years, without name, email, IP or device details.
• Health data after you withdraw the storage consent: 30 days.
• Face check video and photo: 30 days after the moderator's decision.
• Evidence for a chat report: 180 days after the decision.
• Sign-in sessions: 30 days.
• Views of trainer profiles: 12 months.
• Beta waitlist: 12 months after the application last changed.
• Messages from the form on the Contact page: 12 months after they are sent or we reply.
• Server logs and backups: per the hosting settings; we aim for no longer than 30 days.

You can use any of these rights for free. We answer within 30 days.

• Find out what data we hold about you and get a copy: write to support@smugaspace.com from your account's email.
• Correct your data: in your profile and the app settings.
• Delete your account: in the app ("Delete account" in settings) or in your account settings on the website.
• Withdraw any consent: in the app settings or by email.
• Object to analytics and crash reports: the switches in "Privacy" in the app and "Cookie settings" on the website.
• Restrict or object to processing for other reasons: write to us.
• Complain: to the Ukrainian Parliament Commissioner for Human Rights (ombudsman.gov.ua) or, if you live in the EU, to your country's data protection authority.

The website uses the cookies it needs to work and Google Analytics. If your device shows a European time zone (except Ukraine), analytics turns on only after you press "Accept" in the banner. In Ukraine and other countries it is on from the start. You can change your choice at any time in "Cookie settings" at the bottom of the site.

The app asks about analytics once; until you agree, it stays off. Crash reports help us fix bugs; you can turn them off in "Privacy". We don't track you across other apps and we don't use advertising identifiers.

For now Smuga is for people aged 18 and over. You confirm your age when you sign up, and we check your date of birth in the questionnaire. Where the law requires an age check, the app asks the phone's system only for an age range, not your date of birth.

Later Smuga will open to teenagers aged 14–17, only by their trainer's invite and with a parent's or guardian's consent. We will update this policy before that starts. If you learn that a child has a Smuga account, write to us and we will delete it.

• All connections to the app and the website are encrypted (TLS).
• Private files (documents, chat attachments, progress photos, face checks) sit in closed storage and open only through links that expire quickly.
• Access is limited by role: a client sees their own data, a trainer only what you opened to them, moderators only what a check needs.
• Passwords are stored only as a hash and checked against known leaks.

Nobody can promise perfect security, but if a breach affects you, we will tell you and the Commissioner as the law requires.

When we change this policy, we update the date and version at the top. We warn you about significant changes in advance in the app or by email, and if a change affects a consent, we ask for it again.