1. Overview
This Privacy Policy describes how Phorm Labs, Inc. (“Phorm,” “we,” “us,” or “our”) collects, uses, and shares information when you use the Phorm mobile application (the “App”), the website at phorm.app (the “Site”), and any related services (collectively, the “Services”).
By using the Services, you agree to the practices described in this Policy. If you do not agree, please do not use the Services.
2. Information We Collect
Account information
When you create an account, we collect your name, email address, and a securely hashed password (or, if you sign in with Apple, the unique identifier and email relay Apple provides). You may optionally provide your date of birth, biological sex, height, weight, training experience, and goals to personalize the App.
AI features and model providers
Phorm uses DeepInfra to run its cloud AI models. Standard AI requests use MiMo V2.6 Pro. When enabled for a verified Premium subscription, workouts, recovery plans, and recorded form reviews use DeepSeek V4.1 Flash 1017 with Max reasoning. MiMo may handle a request when DeepSeek is unavailable. We no longer send AI requests to Google Gemini.
Premium DeepSeek processing is planned and is not yet enabled. Before enabling any material change to data processing, we will provide the advance notice described in Section 12.
Optional AI workout and recovery generation sends selected training details through our Cloudflare proxy over encrypted connections: preferences, goals, experience, equipment, reported injuries or constraints, body weight, recent exercise and performance summaries, form-score summaries, and derived readiness scores. Raw sleep, heart-rate, and HRV measurements remain on your device. We do not attach your name, email, or device identifier to AI requests.
Video and pose data
Exercise form analysis is optional and available without payment. Before you submit a recording, the App explains how it will be processed:
- The camera records video only; no audio is captured. Recordings are temporary and may identify you or other people in the frame.
- Choosing to analyze a recording sends the compressed video and exercise name through our Cloudflare proxy. Eligible Premium requests also include up to 30 timestamped images sampled from that recording. Images are prepared in memory on your device, without saving additional image files.
- Our proxy sends video to DeepInfra-hosted MiMo, or sampled images to DeepInfra-hosted DeepSeek. If DeepSeek is unavailable, MiMo may review the compressed video. Sampling can miss movement between images.
- The recording is deleted from your device after successful analysis, when discarded, or when you close the recorder. After a failed analysis, it remains locally available for retry until you discard it or close the recorder.
Live frames and pose measurements used by the optional on-device movement-guide preview stay on your device. They are not uploaded as part of that preview.
Your data is not used to train AI models
Phorm does not use your data to train AI models. DeepInfra's terms also prohibit training on inputs and outputs processed by its hosted models. This covers the prompts, training details, videos, sampled images, and generated responses sent through our DeepInfra-hosted MiMo and DeepSeek integrations.
Our proxy does not persist AI request content or responses. DeepInfra provides inference under its zero data retention commitment. We do not use its file storage, batch processing, or paid cache-retention features. Temporary processing and in-memory caching can occur.
This does not mean all operational records are deleted immediately: DeepInfra's terms allow non-content usage and billing records, legally required records, and records needed to address fraud, security incidents, or abuse. See its Data Privacy documentation and Terms of Service.
Before this October 21, 2026 update, workout and recovery requests could use Google Gemini. Previously submitted data remains subject to Google's terms applicable when it was processed; this change does not retroactively change that processing.
Health and biometric data
With your explicit permission, Phorm reads the following from Apple HealthKit and connected wearable integrations (Apple Watch, Whoop, Oura, Garmin, Fitbit):
- Sleep duration, stages, and efficiency
- Heart rate variability (HRV)
- Resting heart rate (RHR)
- Active energy, workout history, and steps
- Body weight and body composition (if you log it)
This data is used to compute your Readiness Snapshot and to auto-regulate your daily training prescription. We never sell or share Health data with advertisers or data brokers, and Health data is treated as a special category subject to the additional safeguards described in Section 5.
Usage and device information
We automatically collect basic technical information when you use the Services: device model, OS version, App version, IP address (only at the request boundary; we do not log it persistently), crash reports, and aggregated, de-identified feature usage. We use this information to keep the App stable and improve performance.
Payments and subscriptions
Subscriptions to Phorm Pro are processed by Apple through the App Store. We do not receive or store your payment card information. We receive only a transaction identifier and the entitlement that lets us unlock Pro features for your account.
3. How We Use Information
- To provide the core service: to compute form scores, generate AI feedback, calculate Readiness, and prescribe and adjust your training.
- To operate your account: authenticate you, sync your training history across devices, and manage your subscription.
- To improve Phorm: we use aggregated, de-identified usage and performance measurements to improve the app's reliability and usability. We do not use your training history, health data, recordings, prompts, or AI responses to train models.
- To communicate with you: service announcements, security notices, billing receipts, and (only if you opt in) product updates.
- To keep the Services secure: to detect abuse, prevent fraud, enforce our Terms, and comply with legal obligations.
4. How We Share Information
Phorm does not sell your personal information. We share information only in the limited circumstances below:
- Service providers who process information on our behalf under strict confidentiality and data-protection agreements (e.g., cloud hosting, error monitoring, transactional email).
- Cloud AI features: Cloudflare processes requests in transit. DeepInfra operates MiMo and DeepSeek to generate workouts, recovery plans, and form feedback using the information described in Section 2. Purchase proofs are not sent to DeepInfra.
- Wearable and Health integrations that you explicitly connect, only the scopes you grant and only for the purposes described above.
- Legal compliance and safety, when required by law, subpoena, or to protect the rights, property, or safety of Phorm, our users, or the public.
- Business transfers in connection with a merger, acquisition, or sale of assets, in which case we will notify you and your data will continue to be protected by a policy at least as protective as this one.
5. Special Treatment of Health Data
Consistent with Apple's App Store Review Guideline 5.1.1(iii) and the HealthKit Terms:
- We do not use Health, HealthKit, or Motion & Fitness data for advertising or any other use-based data mining purposes other than improving health, medical, and fitness management, or for the purpose of health research.
- We do not disclose Health data to third parties for advertising, marketing, or other use-based data mining purposes.
- We never write false or inaccurate data to HealthKit and we never store HealthKit data in iCloud.
6. Data Retention
We retain account data for as long as your account is active. Derived training history is retained until you delete the corresponding session or close your account.
Exercise form recordings are temporary: they are deleted locally after successful analysis, when discarded, or when you close the recorder. Sampled images are prepared in memory without additional image files. Our Cloudflare proxy does not persist videos, images, workout or recovery prompts, or AI responses. DeepInfra's hosted inference retention commitment and exceptions are described above. Operational metadata, such as request times and error status codes, may be retained to operate the service.
When you close your account, we delete or anonymize your personal information within 30 days, except where retention is required by law (e.g., billing records).
7. Your Rights and Choices
Depending on where you live, you may have the right to access, correct, delete, or export your personal information, to object to or restrict processing, and to withdraw consent at any time. You can exercise most of these rights directly in the App:
- Access & export: Settings → Privacy → Export my data
- Delete a session or video: swipe on any session in your training journal
- Disconnect a wearable: Settings → Integrations
- Delete your account: Settings → Account → Delete account (this is permanent)
You may also email us at privacy@phorm.app. We respond to verified requests within 30 days.
8. Security
We implement industry-standard administrative, technical, and physical safeguards: TLS 1.3 in transit, AES-256 at rest, encrypted backups, principle-of-least-privilege access controls, regular third-party penetration testing, and immediate revocation of credentials on offboarding. No system is perfectly secure; we encourage you to use a strong, unique password and enable Sign in with Apple where possible.
9. Children
Phorm is not directed to children under 13 (or under 16 in the EEA and UK). We do not knowingly collect personal information from children. If you believe a child has provided us information, please contact privacy@phorm.app and we will delete it.
10. International Transfers
Phorm is based in the United States. If you access the Services from outside the United States, your information may be transferred to, stored, and processed in the United States and other countries. Where required, we rely on appropriate transfer mechanisms (e.g., Standard Contractual Clauses) for cross-border transfers.
11. California Privacy Rights
California residents have rights under the CCPA/CPRA, including the right to know what personal information we collect, the right to delete it, the right to correct inaccuracies, and the right to opt out of any “sale” or “sharing” of personal information. We do not sell or share personal information as those terms are defined under California law. To exercise your rights, email privacy@phorm.app.
12. Changes to This Policy
We may update this Privacy Policy from time to time. If the changes are material, we will notify you in the App or by email at least 14 days before the changes take effect. The “Effective” date at the top reflects the most recent version.
13. Contact
Questions about this Policy or about your information? Reach us at:
Phorm Labs, Inc.
Attn: Privacy
548 Market St, PMB 60416
San Francisco, CA 94104
privacy@phorm.app