FORMWISE

Privacy Policy

For the Formwise iOS and Android apps, Formwise services, and Aerel website

Contents

1. Who we are and scope

AEREL LTD (company number 17389393), trading as Formwise, is the controller of personal data covered by this policy. Our registered office is 66 Paul Street, London, England, United Kingdom, EC2A 4NA. In this policy, “Formwise”, “Aerel”, “we”, “us” and “our” refer to AEREL LTD.

This policy applies when a person uses the Formwise mobile applications for iOS or Android, related Formwise online services, or the Aerel website pages that link to this policy (together, the “Services”). It also applies to support and privacy enquiries about Formwise. It does not replace the privacy terms of Apple, Google or another third party when that party independently controls data through its own service.

Privacy enquiries and rights requests may be sent to contact@aerel.co.uk or by post to the registered office above. Please write “Privacy request” in the subject line. We may ask for proportionate information to verify identity before acting on a request.

2. Information we collect

The exact information depends on the features a user chooses. Formwise may collect or generate the following categories.

2.1 Sources of information

• Directly from the user, including information entered during registration, onboarding, logging, support or an AI request.
• From the user’s device, when the user grants permission or uses a feature such as camera, photo library or notifications.
• Generated by Formwise, including plans, targets, estimates, reminders, usage limits and progress summaries.
• From Apple, Google and RevenueCat in connection with sign-in, distribution, purchases and subscription entitlements.
• Automatically from infrastructure and security systems when the Services are accessed.

3. How and why we use information

UK data-protection law requires a lawful basis for processing personal data and, where health data is involved, an additional condition. The principal purposes and bases are below. The applicable basis may vary with the context and the user’s location.

Purposes and lawful bases — continued

Where we rely on legitimate interests, we balance those interests against the user’s rights and expectations. Where we rely on consent, consent can be withdrawn at any time for future processing. Withdrawal does not make earlier lawful processing unlawful, but an affected optional feature may no longer work.

4. Health data, photos and AI

4.1 Health and fitness information

Formwise uses health and fitness information to calculate targets, personalise workouts and nutrition guidance, track progress and answer user requests. We rely on explicit consent to process special category health data for these purposes. A user is free not to provide optional information, although results may be less personalised. Formwise does not use health or fitness information for targeted advertising, marketing profiles, credit, employment, insurance or eligibility decisions.

4.2 Camera, photo library and images

Camera or photo-library access is requested only when a user chooses a feature that needs it, such as barcode scanning, meal scanning, progress photos or a body scan. The operating system controls permission. A user can deny or revoke permission in device settings and continue using features that do not require images.

• Meal photos may be transmitted for AI analysis to identify likely foods and estimate portions and nutrients.
• Front and side body photos may be transmitted for image-quality checks and an approximate body-composition estimate. These are not biometric identification templates and are not used to identify a person.
• Progress photos may remain on the device and, where cloud upload is enabled, may be stored in a private user folder. Formwise does not make user images public.
• Users must upload only their own images, must not upload images of children or other people, and should avoid including unnecessary faces, documents or background information.

4.3 AI processing and human review

For AI features, Formwise sends the minimum reasonably necessary input to an authenticated server function, which submits it to OpenAI’s API. Depending on the feature, the input may include a prompt, recent conversation context, selected profile or goal information, meal or workout data, measurements, or an image. Requests use a setting that does not create persistent response application state. OpenAI does not use API inputs or outputs to train its models by default; its standard abuse-monitoring logs may retain inputs, outputs and related metadata for up to 30 days, unless a longer period is legally required or enhanced retention controls apply.

AI output may be wrong, incomplete or unsuitable. Formwise does not use AI to make decisions that produce legal or similarly significant effects. Users can ignore, edit or replace a generated plan or estimate. Authorised personnel may review limited data where reasonably necessary to investigate a user-reported problem, a safety concern, fraud, misuse or a legal obligation, subject to confidentiality and access controls.

5. Sharing and service providers

We disclose personal data only as needed to operate the Services, follow a user’s instructions, comply with law or protect rights and safety. We do not sell personal data and do not share health data with advertisers or data brokers.

Service providers may change as the Services develop. We require processors to act on documented instructions, protect information and provide data-protection commitments appropriate to their role. Independent providers, including Apple and Google, determine their own purposes for some processing.

6. International transfers

Some providers and their infrastructure are located outside the United Kingdom, including in the European Economic Area and the United States. When personal data is transferred from the UK to a country without applicable UK adequacy regulations, we use safeguards required by law, such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another lawful mechanism. We also assess supplementary technical and organisational measures where appropriate. A user may contact us for further information about the relevant safeguards.

7. Retention and deletion

We keep personal data only for as long as reasonably necessary for the purposes described in this policy, including providing an active account, meeting legal duties, maintaining security and resolving disputes. The following schedule states our standard periods or criteria; a shorter or longer period may apply where law, an active dispute or a valid preservation request requires it.

8. Security

We use technical and organisational measures designed to protect personal data, including authenticated access, encrypted network connections, role-based database controls, private storage buckets, separation of server secrets from the app, restricted administrative access, provider due diligence and account-deletion tooling. No internet or storage system is completely secure, so absolute security cannot be guaranteed. Users should use a strong, unique password, protect access to their device and notify us promptly of suspected unauthorised access.

If a personal-data breach is likely to create a risk to individuals, we will assess, contain and notify the UK Information Commissioner’s Office and affected users where applicable law requires it.

9. Your choices and rights

Depending on the circumstances and applicable law, a user may have the right to:

• request access to personal data and information about its processing;
• request correction of inaccurate or incomplete data;
• request deletion of personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• receive certain data in a structured, commonly used and machine-readable format and transmit it to another controller;
• withdraw consent at any time for future processing; and
• complain to a data-protection regulator and, where applicable, seek a judicial remedy.

9.1 In-app and device controls

• Account deletion: Settings → Delete account. This deletes the authenticated Formwise account, associated database records and user files covered by the deletion process.
• Web deletion route: if the app cannot be accessed, email contact@aerel.co.uk from the account email with the subject “Delete my Formwise account”. We will verify the request before deleting the account and associated data.
• Notifications: change reminder selections in Formwise and notification permission in iOS or Android settings.
• Camera and photo library: revoke access in device settings; the related scan/photo features will then be unavailable.
• Subscription: manage or cancel through Apple App Store or Google Play subscription settings. Deleting Formwise does not cancel the subscription.

9.2 Contacting us and the ICO

To exercise a right, email contact@aerel.co.uk. We normally respond within one month, subject to lawful extensions. We do not charge a fee unless a request is manifestly unfounded or excessive and law permits a reasonable fee. If dissatisfied, a user may complain to the UK Information Commissioner’s Office.

ICO: ico.org.uk/make-a-complaint · Telephone 0303 123 1113 · Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, United Kingdom.

10. Children and age restriction

Formwise is intended only for adults aged 18 or over. We do not knowingly collect personal data from anyone under 18 and users must not create an account or submit information for a child. If we learn that a person under 18 has provided personal data, we will take reasonable steps to disable the account and delete the information. A parent or guardian who believes a child has used Formwise should contact us promptly.

11. Website cookies and technical data

The Aerel website may process essential technical data such as IP address, browser type, requested page, referring page, timestamps and security logs to deliver and protect the site. Strictly necessary cookies may be used for security, session continuity or saved privacy choices. Non-essential analytics, advertising or similar cookies will not be placed where consent is required unless the visitor first chooses to allow them, and the website’s cookie control will identify the current cookies and providers. A visitor can also control cookies through browser settings, although blocking essential cookies may affect functionality.

12. Changes and contact

We may update this policy when the Services, providers or law change. The current version will be published at the public privacy-policy URL and in or through the apps, with a revised effective date. We will provide additional notice where a change materially affects users’ rights or requires renewed consent. Earlier versions may be requested from us.

Controller contact