Privacy Policy

This policy explains which personal data we process when you use the Kavi app, the website kavi.fit or our services, why, on what legal basis, who we share it with, and what rights you have. This English version is a translation of the German version.

1. Controller

Softure UG (haftungsbeschränkt), represented by its Managing Director Mohamed Hamda
Scharfenberger Str. 28, 13505 Berlin, Germany
Phone: +49 152 05290170
Email: customers@softure-ug.de

We are currently not required to appoint a data protection officer (Art. 37 GDPR, § 38 BDSG). You can reach us about any privacy matter at the address above.

2. The short version

• Kavi processes health data (meals, training, weight, sleep, health conditions, photos) — only with your explicit consent and only to coach you.
• The AI coach runs on Anthropic (USA). Anthropic processes the data only on our behalf, does not use it for training, and deletes it after 30 days by default.
• Our servers and database are in Germany (Contabo).
• No advertising, no selling of data, no tracking on the website, no analytics cookies.
• You can reset your data or delete your account in the app at any time.

3. Website kavi.fit

3.1 Visiting the website, server logs

When you visit, our server processes technically necessary data: IP address, date and time, page requested, referrer, browser and operating system. This is needed to deliver the site and keep it secure (defending against attacks). Legal basis: Art. 6(1)(f) GDPR (legitimate interest in secure operation). Logs are kept only briefly in size-limited rotating files that are continuously overwritten, unless needed to investigate a security incident. Hosting: Contabo GmbH, Munich, on servers in Germany, as our processor.

3.2 No cookies, no tracking, fonts served locally

We use no cookies and no analytics or advertising tools. Fonts are loaded from our own server, not from Google. In your browser we only store your language choice (local storage) so the site stays in your language; this is necessary for the function you asked for (§ 25(2) No. 2 TDDDG).

3.3 Forms

• Waitlist / early access: your email address and language, to tell you about the launch and access (Art. 6(1)(b) GDPR — at your request). Unsubscribe anytime by email, and we delete the address.
• Coach application: name, email, experience, specialties and your text, to review your application (Art. 6(1)(b) GDPR). If your application is declined, we delete the data after 6 months.
• Cancellation and withdrawal: name, email, contract and your details, to process your notice and confirm receipt (Art. 6(1)(c) GDPR with §§ 312k, 356a BGB). We keep them for 3 years as proof (limitation period).
• Account page: sign-in with your Kavi account to see your plan (see section 7).

3.4 Contacting us by email

If you write to us, we process your message and contact details to reply (Art. 6(1)(b) or (f) GDPR). We delete the correspondence once it is settled and no retention obligations apply.

4. The Kavi app

4.1 Account

Email address, password (only as a secure hash), optionally your name, language, time zone, role (client or coach) and the record of your acceptance of the Terms and your consents (version, date, time). If you sign in with Apple or Google, we receive your email address (with Apple possibly an anonymous relay address), an identifier and possibly your name. To verify your email address we send an email via Resend. Legal basis: Art. 6(1)(b) GDPR (contract); for the consent record, Art. 6(1)(c) GDPR.

4.2 Health and fitness data

To coach you, we process: goal, experience, equipment, training days, sex, year of birth, height, activity level, answers to the health screening questions, health conditions, allergies and diet, meals and nutrients, water, supplements, workouts, plans, weight and body measurements, fasting settings, and your chat messages. From these we calculate targets (e.g. calories and macros) and adapt them to your progress.

Legal basis: your explicit consent under Art. 9(2)(a) GDPR, which you give in the app before first use and which we store with date and time. You can withdraw it at any time with effect for the future by resetting your data or deleting your account in the app (Settings → Danger zone) or by writing to us. Kavi cannot coach you without this data, so withdrawal ends the coaching features. It does not affect the lawfulness of processing before the withdrawal.

4.3 AI coach (Anthropic)

When you chat with the AI coach, we send your message, any attached photo and the part of your data needed for the reply (e.g. targets, today's entries, plan, health notes) to Anthropic, which generates the reply. Anthropic acts as our processor, may not use the data to train its models, and deletes inputs and outputs within 30 days by default (longer only where Anthropic must review content for breaches of its usage policies or is legally required to). Provider: Anthropic Ireland Limited (Dublin) and Anthropic PBC (San Francisco, USA). Transfers to the USA are based on the EU Standard Contractual Clauses in Anthropic's data processing agreement.

The AI coach does not make decisions with legal or similarly significant effects on you (Art. 22 GDPR). It makes suggestions that you decide on. Safety rules (e.g. minimum calories) are built into the system.

4.4 Photos

• Photos in the AI chat (e.g. a meal): stored with your conversation and sent to Anthropic for analysis.
• Photos in the coach chat: visible only to you and your coach while you work together; we remove location and other metadata.
• Progress photos (optional): visible only to you (not to coaches), without metadata; deletable one by one.

Legal basis: Art. 9(2)(a) GDPR (consent, section 4.2).

4.5 Apple Health / Health Connect (optional)

Only if you connect it in Settings, Kavi reads — read-only — steps, active energy, sleep duration, workouts (type, start, duration, energy), body weight and resting heart rate. Kavi never writes to Apple Health. Daily summaries are sent to our servers and used for your coaching (including by the AI coach via Anthropic, section 4.3). We never use this data for advertising and never sell it. Legal basis: your separate explicit consent (Art. 9(2)(a) GDPR) when connecting. When you disconnect, syncing stops immediately and the synced data is deleted from our servers. For Health Connect, the Health Connect Permissions policy also applies, including the Limited Use requirements.

4.6 Food search

When you search for a product or scan a barcode, the search term or barcode is looked up in the open database Open Food Facts — via our server, without personal data.

4.7 Location, gym and coach search

Optionally, you can give a home area and your gym so we can show you coaches nearby. Kavi does not use your device's GPS for this: what you type (e.g. "Berlin Mitte" or the gym's name) is looked up via our server at OpenStreetMap (Nominatim, OpenStreetMap Foundation, United Kingdom — EU adequacy decision), without any link to you. We store the chosen coordinates and label. Legal basis: Art. 6(1)(b) GDPR.

4.8 Push notifications

If you allow notifications, we store a device token and your settings (times, quiet hours). Delivery runs through Apple Push Notification service or Google Firebase Cloud Messaging; they receive the token and the text, which never contains health details. Legal basis: your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG), which you can withdraw in the app's or your device's settings.

4.9 Crash reports (if enabled)

To fix bugs, technical crash reports may be sent to Sentry (Functional Software, Inc., USA): device type, app version, error message. We filter out name, email, messages and health data beforehand. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a working app).

4.10 Telling us what you want (coaches and gyms)

While coaches and gyms are not yet available, you can tell us in the Coach tab that you want a coach (how you'd like to train, your budget, your goal) or name your gym and city. We store your answers with your account to decide what to build and where, and, if you choose, to tell you when it starts. If you allow it, we may tell a gym how many members asked for it, never who. Legal basis: Art. 6(1)(f) GDPR (planning our service) and, for the launch message, Art. 6(1)(a) GDPR. You can change your answers anytime; they are deleted with your account.

5. Coaching with a coach

• Requests and chat: when you request a coach, they see your name, your message and the package you chose. Messages and photos in the coach chat are visible to you and the coach.
• Your data and your coach: during an active, paid coaching, your coach can see your fitness and progress data in Kavi and create plans for you (not your private progress photos). When the coaching ends, their access ends. This sharing is covered by your consent (section 4.2) and is the core of the coaching you booked.
• In-person sessions: time, place and note for both of you, including reminders.
• Reviews: if you review a coach, the review is shown publicly on their profile with a shortened name ("Sarah K.").

Coaches are separate controllers for the data they process in their coaching. Legal basis for the platform: Art. 6(1)(b) GDPR, and for health data Art. 9(2)(a) GDPR.

6. Kavi through your gym (Kavi for Gyms)

If you join a gym with its code, QR code or invite, you use Kavi included with your membership. Before you join, the app shows exactly what the gym sees, and you confirm it.

• What your gym sees: your name and email address, when you joined (and if you leave or are removed), whether you used Kavi in a calendar month (not what you did), which gym coach you work with, and the gym classes you book and whether you attended. Gym programs are shown to the gym only as totals.
• What your gym never sees: your meals, weight, workouts, photos, Apple Health data and your chats with Kavi. A gym coach sees your training and nutrition only after you accept that coach (your explicit consent, Art. 9(2)(a) GDPR), like any Kavi coach (section 5).
• Roles: we remain the controller for your Kavi account and everything you log. We pass the membership information above to your gym because you asked to use Kavi through it (Art. 6(1)(b) GDPR); we also use whether you were active in a month to bill the gym (Art. 6(1)(f) GDPR). Your gym is a separate controller for this information. The gym's classes, bookings, attendance, news and programs in Kavi we process on the gym's behalf, under a data processing agreement with it (Art. 28 GDPR).
• Gym news and invites: your gym can send you news (as a push notification, which you can turn off) and may invite you by email; we send these emails on the gym's behalf.
• Leaving: you can leave in the app at any time; the gym can also remove you, and membership ends if the gym's contract ends. You keep your account and everything you logged; Kavi then runs on your own plan.
• Retention: the monthly "used Kavi" record is kept for 24 months as billing evidence, then deleted; invoices to the gym contain only the number of active members. When a gym's contract ends, its gym data in Kavi (rosters, classes, bookings, news, programs) is deleted after 90 days.

For gym staff (owners, admins, coaches) we process their account and role and what they do in the gym console, to provide the service to the gym (Art. 6(1)(b) and (f) GDPR). The gym console's AI helper (Anthropic, section 4.3) only sees the gym's totals, schedule and programs, never members' health data.

7. Payments

• Stripe (Stripe Payments Europe Ltd., Ireland, and Stripe, LLC, USA): processes payments for coaching and gyms' invoices for Kavi for Gyms. Stripe receives name, email, payment details and amount; we never see full card details. Stripe is partly a separate controller (e.g. fraud prevention). US transfers: EU-US Data Privacy Framework.
• Apple: for App Store purchases, Apple is the seller and a separate controller. We receive no payment details from Apple.
• RevenueCat (RevenueCat, Inc., USA): manages App Store subscription status and receives your account ID and purchase receipts, no health data. US transfer: EU Standard Contractual Clauses.

Legal basis: Art. 6(1)(b) GDPR; we keep invoice and accounting records for 8 or 10 years due to legal obligations (Art. 6(1)(c) GDPR, § 147 AO, § 257 HGB).

8. Data of coaches

For coaches we also process profile details (name, photo, texts, certificates, gyms, prices, reviews), which are shown publicly in Kavi, as well as payout data via Stripe Connect and earnings. Under the German Platform Tax Transparency Act (PStTG) we must collect certain data from coaches (including name, address, date of birth, tax identification number, VAT ID, bank account and earnings) and report it annually to the Federal Central Tax Office (Art. 6(1)(c) GDPR). We check VAT IDs with the European Commission's VIES service, and keep these tax data for 10 years after the reporting year (§ 23 PStTG). Details in the Terms for Coaches.

9. Recipients and processors at a glance

• Contabo GmbH, Germany — hosting, database, backups (in Germany)
• Hetzner Online GmbH, Germany — encrypted off-site copies of the backups (Falkenstein, Germany; kept 14 days, readable only with our key)
• Anthropic (Ireland/USA) — AI coach; Standard Contractual Clauses
• Stripe (Ireland/USA) — payments; Data Privacy Framework
• Apple (Ireland/USA) — App Store, push, Sign in with Apple
• Google (Ireland/USA) — Firebase Cloud Messaging, Sign in with Google; Data Privacy Framework
• RevenueCat (USA) — App Store subscription status; Standard Contractual Clauses
• Resend (USA) — sending emails; Data Privacy Framework
• Functional Software / Sentry (USA) — crash reports, if enabled; Data Privacy Framework
• Open Food Facts (France) and OpenStreetMap Foundation (United Kingdom) — lookups without personal data

We have agreements under Art. 28 GDPR with our processors. Beyond that we share data only if we are legally required to (e.g. with authorities or the tax office) or you have consented. We do not sell data.

10. Retention

• Account, health and chat data: as long as your account exists. If you delete your account, we delete this data from the database immediately; it disappears from backups within 14 days at the latest.
• Reset in the app deletes all your entries immediately; the account remains.
• Invoice and accounting records: 8 or 10 years (legal obligation).
• Gym membership: the monthly "used Kavi" record 24 months; a closed gym's gym data 90 days (section 6).
• Cancellation and withdrawal notices: 3 years.
• Server logs: briefly, in continuously overwritten files.

11. Security

We encrypt all connections (TLS), store passwords only as hashes, separate users' data technically at database level (row-level security), restrict access to what is necessary, and make regular backups accessible only to administrators.

12. Your rights

You have the right to

• access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17) and restriction of processing (Art. 18);
• data portability (Art. 20);
• withdraw consents with effect for the future (Art. 7(3));
• object to processing based on legitimate interests, on grounds relating to your particular situation (Art. 21);
• lodge a complaint with a supervisory authority (Art. 77), e.g. the Berlin Commissioner for Data Protection and Freedom of Information, which is responsible for us: Alt-Moabit 59–61, 10555 Berlin, datenschutz-berlin.de.

Write to us at customers@softure-ug.de. We reply within one month.

13. Minors

Kavi is intended for people aged 16 and over. If we learn that an account belongs to someone younger, we delete it.

14. Changes

We update this policy when Kavi or the law changes. For material changes, we inform you in the app and ask for your consent again where required.