Privacy Policy

Last updated: September 14, 2026

1. Controller

GCO Life
Zürcherstrasse 242
8500 Frauenfeld
Switzerland
Email: support@gcolife.com

There is no legal obligation to appoint a data protection officer (solo developer, fewer than 250 employees, no extensive profiling within the meaning of Art. 10 revDSG (Swiss Federal Act on Data Protection)). For privacy matters you can contact us directly at the address above.

2. What data we collect

GCO Life collects the following data in order to provide the app's functions:

Account data:

• Email address (for registration and login)
• Name (optional, for personalization)

Profile and fitness data:

• Age, gender, weight, height
• Fitness level, training goals, nutrition preferences
• Injuries, allergies (if provided)

Usage data:

• Daily check-in data (sleep, energy, stress, mood)
• Training data (exercises, weights, duration)
• Nutrition data (meals, calories, macronutrients)
• Cardio and recovery data

Apple Health (HealthKit):

• Only with your explicit consent
• Workout data and activity data
• This data is processed exclusively locally and within your protected account

Push notifications (Firebase Cloud Messaging):

• We use Firebase Cloud Messaging (FCM) for coach reminders and workout reminders
• An anonymous FCM token is generated on your device and linked to your account
• The token contains no directly identifying data and is used only to deliver notifications
• Opt-out: you can disable push notifications at any time in your iOS or Android device settings

3. How we use your data

Your data is used exclusively for:

• Providing personalized coaching recommendations
• Calculating the Readiness Score and progress analyses
• AI-generated training and nutrition plans
• Improving the app's functionality

4. Data storage

Your data is stored in Google Firebase (location: Europe, Belgium). Transmission is encrypted (TLS/SSL). Access to your data is protected by Firebase Authentication, Firestore Security Rules and encryption at rest.

5. AI providers (Anthropic & OpenAI)

GCO Life uses AI models from two providers to deliver the coach features:

• Anthropic (Claude Haiku 4.5 / Sonnet 4.5): Primary model for coach responses, pattern detection and tool use since version 1.8.3 (production).
• OpenAI (gpt-4o): Used for image analysis (meal photo scan) and as a fallback if Anthropic is temporarily unavailable (e.g. rate limit/529).

Which categories of data are transmitted:

• Training, nutrition, cardio and recovery data
• Sleep, energy, stress and mood values from the daily check-in
• Coach memory (personality, preferences, remembered topics)
• For photo scan: the meal image taken by the user (to OpenAI)

What is NOT transmitted: email, real name, date of birth, exact address, raw Apple HealthKit data.

Place of processing: USA (Anthropic, Inc. and OpenAI, L.L.C.). Basis for the transfer to the USA: the European Commission's Standard Contractual Clauses (SCCs) together with supplementary safeguards and, where the recipient is certified, the EU-U.S. Data Privacy Framework (Swiss-U.S. Data Privacy Framework for Switzerland). Both providers are certified under the EU-U.S. and Swiss-U.S. Data Privacy Framework.

Legal basis: performance of a contract (Art. 6(1)(b) GDPR and Art. 31(2)(a) revDSG respectively) — the AI processing is a core part of the app's functionality.

No training data for AI models: Both Anthropic and OpenAI have contractually assured us that your data is not used to train their models (API use, no consumer plan).

6. Disclosure to third parties

We do not pass your personal data on to third parties, with the following exceptions:

• Google Firebase (Google Ireland Limited): hosting, database, authentication, push notifications
• Anthropic (USA): AI coach (Claude), see section 5
• OpenAI (USA): image analysis and AI fallback, see section 5
• Apple (App Store): subscription management and payment processing
• Google Analytics / Firebase Analytics / Crashlytics: anonymized usage and stability statistics
• Meta Platforms Ireland Limited: advertising tracking, see section 7
• Open-Meteo (weather data): when the weather forecast is retrieved, your approximate coordinates are sent to the Open-Meteo API — without an identifier, without an account, and not stored by us
• Open Food Facts (France), UPCitemdb (USA) and Brocade (USA) — barcode and food lookup: when you scan a barcode or search for a food, only the barcode or search term and, technically, your IP address are sent to these databases — no account, no identifier, no health data
• ExerciseDB (image CDN): exercise animations are loaded from an external image server; technically this transmits your IP address, nothing else

We do not sell personal data and will not do so in the future either.

7. Advertising tracking and third parties (Meta)

GCO Life uses the Meta SDK (Facebook SDK) from Meta Platforms Ireland Limited to measure the effectiveness of our advertising campaigns and to further develop our app. We are transparent about what happens in the process.

After installing iOS version 1.9.9 (build 67) or later, automatic and manual advertising events, advertising ID collection and account matching are enabled only with your explicit App Tracking Transparency consent. Declining or withdrawing consent disables these client-side advertising operations. If the app is closed, the server learns of a withdrawal when the app next contacts it. First-party app analytics is separate.

Older installed versions may continue to send automatic and manual app events and signals about completed workouts, logged meals and check-ins to Meta.

Which data is transmitted to Meta after consent:

• Standard app events (automatic): app installation, app open, app activity
• Custom events: registration completed (CompleteRegistration), subscription started (Subscribe), content viewed (ContentView), tutorial completed (TutorialCompletion)
• iOS: advertising identifier (IDFA) — only if you explicitly consent to app tracking via the iOS system dialog ("App Tracking Transparency")
• Android: Google Advertising ID (AAID) — can be reset or disabled at any time in the device settings
• Device data: device type, operating system version, approximate time zone, IP address (truncated by Meta immediately)

What Meta does NOT receive from iOS version 1.9.9 (build 67):

• From iOS version 1.9.9 (build 67): no signals about completed workouts, logged meals or check-ins. From this version, also no weight, height, training content, sleep data or meal details
• No Apple HealthKit data (this is not transmitted to Meta)
• No coach conversations or AI-generated content
• No location data; only your country (2-letter code) is transmitted in hashed form as part of Advanced Matching
• No images or audio recordings
• No plain-text account data — email, name, date of birth, gender and country are hashed before transmission. In addition, a pseudonymous user identifier (app-internal ID, no name, no email) is transmitted to attribute the events

What Meta uses this data for:

• Measuring the success of our advertising campaigns (conversion tracking)
• Attributing app installations to preceding ad contacts (attribution)
• Aggregated reports on app usage (anonymized, without attribution to individuals)
• SKAdNetwork and Aggregated Event Measurement (Apple's privacy-friendly tracking framework)
• Personalized ad targeting — only if you have consented via ATT on iOS or have not set an opt-out setting on Android
• Building Custom Audiences and Lookalike Audiences in our Meta advertising account

Legal basis:

• Switzerland (revDSG): consent pursuant to Art. 6(6) and (7) revDSG as well as an overriding private interest in the effectiveness of our advertising (Art. 31(1) revDSG)
• EU/EEA (GDPR): consent pursuant to Art. 6(1)(a) GDPR (given via the iOS ATT dialog or the system-level advertising settings on Android)

Data transfer to the USA: Meta also processes data in the USA. Basis for the transfer: the European Commission's Standard Contractual Clauses (SCCs) together with supplementary safeguards and, where the recipient is certified, the EU-U.S. Data Privacy Framework (Swiss-U.S. Data Privacy Framework for Switzerland). Meta is certified under the EU-U.S. and Swiss-U.S. Data Privacy Framework.

Retention period: Meta stores app event data for 25 months by default for advertising reporting purposes. Aggregated data may be stored for longer.

Your choices:

• iOS: You can withdraw app tracking at any time and disable it under Settings → Privacy & Security → Tracking → GCO Life. Once withdrawn, no further Advanced Matching data is sent to Meta
• Android: Settings → Google → Ads → Delete advertising ID or "Opt out of Ads Personalization"
• Complete deletion: Write to us at support@gcolife.com with the subject "Delete Meta data". We will delete your user identifier at Meta within 30 days
• Account deletion: If you delete your GCO Life account, all data transmission to Meta stops immediately

Meta privacy policy: https://www.facebook.com/privacy/policy

8. Apple HealthKit

GCO Life can be connected to Apple Health (HealthKit). Special rules apply to HealthKit data:

• HealthKit data is only read with your explicit consent
• HealthKit data is not passed on to advertising third parties. Daily aggregates (steps, calories, sleep duration, HRV, resting heart rate) feed exclusively into your coach responses and are transmitted for that purpose to our AI processors (section 5) — never to Meta, never for advertising
• HealthKit data is not used for advertising purposes
• HealthKit data is not stored in iCloud

9. Retention periods

We store your data only for as long as is necessary to provide the app's functions or to comply with statutory retention obligations. Specifically:

Data category	Retention period
Account data (email, name)	until the account is deleted
Training, nutrition, cardio, recovery data	until the account is deleted
Sleep, stress, check-in data	until the account is deleted
Coach memory (personality, preferences)	until the account is deleted
Crash logs (Crashlytics)	90 days
Meta tracking events	per Meta policy, max. 24-25 months
Backup snapshots (Firebase)	max. 30 days after account deletion
FCM token (push)	until uninstallation or account deletion
Deletion record (technical account identifier/UID, status, time)	indefinitely; without name, email address or content
Pseudonymised check value of the sign-in identity (trial abuse prevention)	180 days from the start of the trial, also after account deletion; deleted automatically within 24 hours of expiry

10. Your rights

You have the right to:

• Access: Find out what data we have stored about you
• Deletion: Request the deletion of your data and your account
• Rectification: Have incorrect data corrected
• Data portability: Receive your data in a common format
• Withdrawal: Withdraw your consent at any time (e.g. HealthKit access, Meta tracking)
• Restriction: Request the restriction of processing
• Objection: Object at any time, on grounds relating to your particular situation, to processing based on our overriding or legitimate interest (e.g. trial abuse prevention, section 13) – Art. 21 GDPR, Art. 30 para. 2 lit. b Swiss FADP

Write to us at support@gcolife.com to exercise one of these rights.

11. California and other US states

• We do not sell your personal information — there is no data trading and no data broker
• With your consent we share advertising events with Meta to place you in audiences. Under California law this counts as ‘sharing’
• You can withdraw at any time: iOS Settings → Privacy & Security → Tracking. After that, no further advertising events are sent
• Health, cycle and Apple Health data are excluded from this sharing
• You have the right to know, correct, delete and opt out — and will not be treated differently for exercising it

12. Right to lodge a complaint

If you believe that the processing of your data violates applicable data protection law, you have the right to lodge a complaint with a supervisory authority:

• Switzerland: Federal Data Protection and Information Commissioner (FDPIC/EDÖB), Feldeggweg 1, 3003 Bern, Switzerland — www.edoeb.admin.ch
• EU/EEA: the national data protection authority responsible for your place of residence (e.g. BfDI in Germany, Datenschutzbehörde in Austria)

13. Data deletion

You can delete your account at any time directly in the app (Profile → Delete account) or by emailing support@gcolife.com. When you delete in the app we remove your profile, your training, nutrition, check-in and health data, your coach history, uploaded documents and your sign-in account – usually immediately, and within 30 days at the latest; deletion requests by email are likewise processed within 30 days. Backup snapshots are overwritten automatically no later than 30 days after deletion.

Exceptions to deletion:

• Deletion record: We keep, indefinitely, a record containing your technical account identifier (UID), the status and the time of deletion (no email address, no name, no content) so that a deleted account cannot be restored by accident.
• Abuse prevention for the free trial: For 180 days from the start of the trial we retain a pseudonymised check value (SHA-256 hash) of your sign-in identity (email address or the user identifier of the sign-in provider such as “Sign in with Apple”). This prevents the one-time free trial from being claimed repeatedly by deleting and re-registering. The check value contains no plain text, is not linked to your former content and is deleted automatically once the period expires, within 24 hours at the latest. The legal basis is our overriding private interest in preventing abuse (Art. 31 para. 1 Swiss FADP) and our legitimate interest (Art. 6(1)(f) GDPR) respectively.

Right to object: You may object at any time, on grounds relating to your particular situation, to processing based on our overriding or legitimate interest – in particular the trial abuse prevention – (Art. 21 GDPR; Art. 30 para. 2 lit. b Swiss FADP). To do so, contact support@gcolife.com.

14. Children

GCO Life is not directed at persons under the age of 16. Minimum age: 16. Anyone younger may not use GCO Life, not even with a parent's consent. We do not knowingly collect data from children under the age of 16.

15. Changes

We may update this privacy policy from time to time. The current version is always available on this page. In the event of material changes, we will inform you in the app.

16. Contact

If you have any questions about data protection, contact us at:
support@gcolife.com