REGENPRO | PRIVACY POLICY | VERSION 1

RegenPro Privacy Policy

Version 1

1 About RegenPro

REGENPRO PTY LTD (ACN 702 825 938) (RegenPro, we, us or our) provides the RegenPro website at regenpro.app and the RegenPro fitness and wellbeing app. This policy explains how personal information is collected, used, held and disclosed in connection with those services, and how to contact us about privacy.

The information involved depends on the features you use. To contact us about this policy or your personal information, use the privacy contact in section 16.

2 Information we collect

Account and profile information includes your name, email address, account identifiers and sign-in information, together with profile information you provide, such as age and sex.

Training and progress information includes your goals, training experience, available time and equipment, programmes, workout history, sets, repetitions, weights, effort ratings, exercise feedback, check-ins and measurements you enter.

Health and nutrition information can include injuries, physical limitations, discomfort, sleep or readiness, body measurements, dietary preferences and restrictions, and other health information you choose to provide. Coach messages and uploaded reports can also contain health information. Some of this information is sensitive personal information.

Coach information includes your messages, the context provided to the AI coach, its responses, and generated summaries or training notes associated with you. Information generated about you can itself be personal information, even when you did not enter it directly.

Support information includes messages, requests, and feedback you send to us. Please avoid including unrelated health information or information about other people.

3 How information is collected

We collect information you provide when you create an account, complete your profile, log training, check in, use the coach, upload a report or contact us. The app also generates information such as programmes, summaries and coach responses from the information you provide.

Where lawful and practicable, you can contact us anonymously or using a pseudonym. We may need to identify you to manage an account or respond to a request concerning personal information about you.

4 Health information and choices

Health information is used to personalise the relevant training and wellbeing features. Reading this policy, accepting general terms or continuing to use the app does not by itself amount to consent to every use of health information. When you create an account, we ask for your consent to handle health information as a separate choice from accepting our terms, and the consent box is not pre-ticked.

You can choose not to provide optional health information. A feature may be unavailable or less personalised if it needs information you do not provide. Use the privacy contact in section 16 to discuss consent, ask us to stop a consent-based use, or request deletion. Withdrawal, account deletion and subscription cancellation are different requests; withdrawing consent does not reverse processing that has already occurred.

Only provide information about another person where you have authority to do so. Do not include unnecessary sensitive information in messages or uploads.

5 Reports and AI processing

When you upload a report, the complete document or image, including any health information it contains, is sent to our hosting and third-party AI providers for processing. This includes information beyond the summary or measurements retained in the app.

Extracted information, including the report summary, name, date and measurements, is stored with your profile in our cloud systems. Processing is not confined to your device. Deleting a local file or clearing your browser does not necessarily remove information already stored or processed by a provider.

RegenPro does not diagnose conditions, interpret results for medical purposes or provide treatment. Take questions about a scan or test result to the health professional who ordered it. AI extraction can make mistakes, so check the information used in your training profile.

6 Why we use information

We use information relevant to your chosen features to create and manage your account; prepare and adapt training programmes and nutrition guidance; record workouts and progress; answer coach and support messages; operate and troubleshoot the service; protect against misuse; and meet applicable legal obligations.

Personal information supplied for coaching is not blanket permission for unrelated uses. Any optional marketing consent is separate from the information needed to provide the service.

7 AI coaching and automated decisions

RegenPro uses third-party AI services to generate coaching responses and support automated training guidance. Depending on the feature, the information sent for processing can include your profile, goals, programme, recent training history, check-ins, messages, and health or nutrition information you have provided. Report uploads are processed as described in section 5. Under our AI provider’s commercial terms, these inputs and outputs are not used to train its models by default and are deleted within 30 days unless a longer period applies, for example where content is flagged under its usage policy or must be kept by law.

Automated systems can select or adjust exercises, training volume and progression using this information without a person reviewing every output. These outputs are intended for general fitness and wellbeing, not medical diagnosis, treatment or decisions about access to healthcare.

AI outputs can be inaccurate or unsuitable. Speak to a qualified health professional about an injury, symptom or medical condition. You can contact us to question an output or request correction of personal information associated with you.

8 Service providers and disclosures

Personal information is disclosed to providers where needed to operate the relevant service, with consent where required, or where otherwise authorised or required by law. We do not sell personal information and do not share it for advertising.

We use service providers for account management and cloud storage, hosting and processing, service security, AI coaching and report analysis, support email, and website analytics. They receive information relevant to those functions. AI processing is described in sections 5 and 7.

Website subscriptions use a third-party payment provider.

Support email is handled separately from the in-app AI coach.

We may also disclose relevant information to professional advisers, regulators, courts or law enforcement where reasonably necessary and permitted or required by law, including to respond to a serious threat to life, health or safety.

9 Website technology

The website uses analytics. The app also stores information on your device and in cloud systems. Browser or device settings can be used to clear locally stored information, but this does not necessarily remove information held in cloud systems or by service providers. Clearing local data may sign you out or remove information stored only on that device.

10 Overseas processing

Personal information provided to service providers may be processed or accessed outside Australia. This can include information sent for AI processing. Overseas handling can involve storage in the United States, processing or access by the provider and its subprocessors.

Use the privacy contact in section 16 for questions about overseas handling. The safeguards that apply to overseas handling depend on the relevant provider arrangements and Australian privacy law.

11 Holding and protecting information

Information can be held in the app’s local device storage, synchronised cloud records, AI-processing systems and our email service. The report and coach processing described above can involve health information, not just account details.

No method of storage or transmission is completely secure. Use the privacy contact in section 16 if you believe your personal information has been accessed or disclosed improperly. We will assess reported incidents and respond, including notifying affected people and the relevant regulator where required by law.

12 Retention and deletion

Retention depends on the purpose for which information is held and applicable legal requirements. Account closure, removal from active systems, provider retention and backup expiry are separate matters. Deleting information on one device does not necessarily remove cloud copies or information on other devices.

You can request account closure or deletion using the privacy contact in section 16. We may need to verify your identity. We will explain the information covered by the request, any information that must be retained and why, and the expected handling timeframe. This policy does not promise immediate removal of every copy or a fixed backup-deletion period.

When information is no longer needed for a permitted purpose and no law requires it to be kept, it should be destroyed or de-identified as required by applicable law. Account deletion does not by itself establish that a separately managed subscription has been cancelled.

13 Access and correction

To request access to, or correction of, personal information we hold about you, use the privacy contact in section 16. Tell us which account or information your request concerns. We may need to verify your identity using information appropriate to the request.

We will respond within a reasonable period and in accordance with applicable law. If we cannot provide access or make a correction, we will explain why where lawful and tell you how to complain. If we disagree about a correction, you can ask us to associate a statement of your position with the information.

You can also use this contact to ask about AI processing, consent or deletion. A request does not guarantee that every record can be removed immediately; any applicable limitations should be explained when the request is handled.

14 Age eligibility

RegenPro is intended for people aged 18 and over.

If you believe we hold information about a person under 18, use the privacy contact in section 16 so that we can investigate and determine the appropriate response.

15 Privacy complaints

Send privacy complaints using the privacy contact in section 16. Please describe what happened, the information involved and the outcome you are seeking. We will consider the complaint, investigate as appropriate and respond. We may request further information and will explain if additional time is needed.

If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner. Information about privacy complaints is available at www.oaic.gov.au/privacy/privacy-complaints.

16 Changes and contact

This policy may be updated as the service or legal requirements change. Material changes to consent-based processing may require a new notice or fresh consent before the changed processing begins.

Privacy contact

REGENPRO PTY LTD

Email: support@regenpro.app

Version 1