Privacy
Policy.

Who we are

The data controller for SmartGains (the iPhone and Apple Watch apps, the servers behind them and this website) is:

Company

Digital Marketing Concept S.R.L.

Registered office

Aleea Lacul Morii 127-129, Entrance A, Floor 8, Apt. 97, District 6, Bucharest, Romania

Tax ID (CUI)

38324560

Trade Register

J40/17115/2017 (EUID ROONRC.J40/17115/2017)

Email

hello@digitalmarketingconcept.ro

"We" and "us" in this policy mean Digital Marketing Concept S.R.L.

What we collect

Your account

• Your email address and name, from the way you sign in (Sign in with Apple, Google or email). With Sign in with Apple you can hide your email: we then only see Apple's private relay address. You can change your name in the app.
• A user ID that links your SmartGains account to your sign-in.
• Your preferences: units, weight step, rest settings, appearance and first day of the week.

Your training

• The workouts and programs you create, with their exercises, sets, targets and earlier versions.
• The workouts you log: every set with its weight and reps, rest, notes, the suggestions SmartGains made and the ones you applied.
• The custom exercises you create, with their equipment and muscles.

Your purchases

If you buy SmartGains Pro, Apple tells us what you bought, when it renews or ends, and the transaction IDs, so the app can unlock Pro on all your devices. Payment is handled entirely by Apple: we never see your card or payment details.

Technical data

When the app talks to our servers, they keep short technical logs (the time, the request, the result and the network address it came from) to keep the service secure and to fix errors.

We do not collect your location, your contacts, your photos, advertising identifiers or anything about how you use other apps.

Apple Health

If you allow it, SmartGains uses Apple Health (HealthKit) on your devices. It writes your workouts and active energy to Health, so they count toward your Activity rings, and it reads heart rate, active energy and workouts to show them during and after a workout.

• Health data stays on your devices. It is not uploaded to our servers; heart rate and energy in your history are read from Apple Health on your iPhone.
• Health data is never used for advertising or marketing, never sold, never shared and never stored in iCloud by SmartGains.
• You can turn access off at any time in the Health app or in the iPhone's Settings. Workouts already saved to Health stay there until you delete them in the Health app.

If we ever offer to store Health data on our servers, it will be a separate option, off by default, that asks for your explicit consent first.

Why we use it

• To run SmartGains (the contract between us, GDPR Art. 6(1)(b)): your account, syncing your training between your iPhone and Apple Watch, the suggestions after every workout, your progress, and Pro.
• To improve the exercise catalog (our legitimate interest, Art. 6(1)(f)): we look at the names, equipment and muscles of custom exercises, grouped by name with a count, to decide which exercises to add to the catalog for everyone. We only see who created one when we open it.
• To keep the service secure and working (our legitimate interest, Art. 6(1)(f)): the technical logs and backups.
• To meet legal obligations (Art. 6(1)(c)), for example keeping records of purchases where the law requires it.
• To answer you when you write to us, using what you send us.

We only send you notifications you asked for (the end of a rest and, during a free trial, a reminder two days before it ends). These are created on your iPhone. We send no marketing.

Where it is stored

Your account and training data are stored on our own servers in the European Union. The connection between the app and our servers is always encrypted (HTTPS), and backups are encrypted and kept in the EU.

The app also keeps a copy of your training on your iPhone and Apple Watch, so it works offline. Logging out deletes that copy from the device.

Who else processes it

We use three providers to run SmartGains. Each one only gets what it needs:

Google (Firebase Authentication)

Sign-in. Holds your sign-in identity (email, name and sign-in method) and nothing about your training. Google acts as our processor under its data processing terms.

Apple

Purchases and Sign in with Apple. Apple processes your payment and subscription under its own privacy policy.

Cloudflare

The network in front of our servers and this website (secure connection, DNS and access control). Requests pass through Cloudflare on their way to our servers.

Google and Cloudflare may process data outside the EU. They do so under the EU–US Data Privacy Framework or the European Commission's standard contractual clauses.

We may also disclose data when the law requires it, for example to answer a valid request from a court or an authority.

What we never do

• We never sell your data and never share it for advertising.
• No tracking, no third-party analytics and no ads in the app or on this website. The App Store label is "Data Not Used to Track You".
• No data of yours is ever sent to an AI provider. We only use AI to help write the descriptions of catalog exercises, from the exercise's name, equipment and muscles.

How long we keep it

• While you have an account, we keep your account and training data.
• Something you delete in the app (a workout, a program, a custom exercise) is kept as a marker for up to 90 days so your other devices also delete it, then removed.
• When you delete your account, everything on our servers is deleted at once: your account, workouts, programs, history and custom exercises. Your sign-in identity is deleted from Firebase, and the Sign in with Apple link is revoked. Backups expire after 30 days, so after that nothing of your account is left in them either. We keep only a record that an account was deleted, without any personal data.
• Technical logs are kept for a short time, no longer than 30 days, unless we need one to investigate a security incident.
• Purchase records are also kept by Apple under its own rules. Deleting your account does not cancel a subscription: cancel it in the App Store first.

Your rights

Under the GDPR you have the right to:

• access your data and get a copy of it;
• correct it;
• delete it;
• take it with you (data portability);
• restrict or object to how we use it, including the catalog improvement;
• complain to a data protection authority. In Romania it is the National Supervisory Authority for Personal Data Processing (ANSPDCP, dataprotection.ro); you can also contact the authority where you live.

You can do most of this yourself in the app: export all your data as a file, change your name and preferences in Settings, and delete your account in Settings › Delete account. For anything else, write to hello@digitalmarketingconcept.ro from the email address of your account. We answer within one month.

This website

smart-gains.com sets no cookies, has no analytics and loads nothing from other sites. It is hosted on Cloudflare, which processes your network address to deliver the pages and protect the site. The only thing the site remembers is the light or dark theme you pick, stored in your browser and never sent to us.

Children

SmartGains is not meant for children under 16. We do not knowingly collect data from them. If you think a child has created an account, write to us and we will delete it.

Changes

If we change this policy, we update it here with a new date. If a change affects how we use your data, we tell you in the app before it applies.

Contact

Questions about your privacy or this policy:hello@digitalmarketingconcept.ro, or by post to Digital Marketing Concept S.R.L., Aleea Lacul Morii 127-129, Entrance A, Floor 8, Apt. 97, District 6, Bucharest, Romania.