Privacy Policy

Last updated: 4 November 2026  ยท  Governing law: Hong Kong SAR

Spotter ("the app", "we", "us") is a fitness-tracking app with an AI pose-analysis coach, workout planner, nutrition logger, and AI health coach. This policy explains what personal data we collect, why we collect it, how it is used and shared, and your rights under the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") and, if you live elsewhere, under the laws described in section 7A.

1. Data Controller

The data controller is the operator of Spotter, contactable at support@spotterhk.com. All requests relating to personal data should be directed to this address.

2. Information We Collect

CategoryWhat we collectHow
Account Email address; encrypted password (stored and managed by Supabase Auth) You provide on sign-up
Profile & body data Name, display nickname, age, gender, height, weight, body-fat %, skeletal muscle mass, target weight, fitness goal, experience level, weekly training frequency, activity level, preferred training time, focus body parts You provide during onboarding and in Profile settings
Workout & training data Exercises performed, sets, reps, weights, training session timestamps, rest intervals, superset / drop-set tags, training plans, cardio activity type / duration / heart rate / calories You log during or after training sessions
Nutrition & hydration data Meal entries (food name, portion, kcal, carbohydrates, protein, fat, fibre), daily calorie & macro targets, daily water intake (ml), water reminder settings You log manually or via AI photo/text analysis
Weight history Body-weight readings with timestamps You log periodically
Camera & workout video data When you use the AI Form Coach, you record or select a short training video (up to 60 seconds). A small number of still frames are extracted from that video and sent to our secure backend, then forwarded to our AI provider to generate form-analysis feedback. The original video file itself is not uploaded โ€” it stays on your device unless you choose to share it. Extracted frames are used only to generate that single analysis response and are not stored by us afterwards. Camera/photo-library accessed only when you use the AI Form Coach
AI coaching & chat content Your chat messages to the AI coach; still frames extracted from workout videos (see above) sent for form analysis; meal photos or text descriptions sent for food recognition; InBody report photos sent for body-composition parsing Transmitted to our secure backend when you use AI features
Apple Health data Today's step count and the latest heart-rate reading (read-only, from Apple HealthKit). We do not write any data to Apple Health. Only if you grant HealthKit permission
Location & motion data During outdoor cardio, your GPS position is used on-device to draw your route map and compute distance and pace. Route coordinates stay on your device and are never uploaded โ€” only aggregate statistics (activity type, duration, total distance, calories) sync to your account. The app also reads step counts and walking distance from the device pedometer to show your daily activity summary. You can revoke the Location and Motion permissions in iOS Settings at any time. Only if you grant Location / Motion permission, during cardio sessions
InBody scan data Photo of your InBody body-composition report. AI extracts weight, body-fat %, muscle mass, and test date. The photo is sent to our AI backend for processing and is not stored beyond the API call. Only when you use the InBody Scan feature
Usage analytics Screen views, feature interactions, sign-up and login events, session duration, collected via PostHog Automatically while you use the app
Crash & error reports Device model, OS version, error stack traces, collected via Sentry when the app encounters an error Automatically on app crash or error
Diagnostic & telemetry data App version, build number, platform, OS version, device model, locale, last-seen timestamp, AI-request latency and feature type (but not content), whether AI or offline fallback answered. If you use the app without an account, this data (plus counts of features used, such as foods added) is tied to a random ID created on your device instead, and is not linked to you or to any account you create later. Automatically at launch and during AI feature use
Feedback Messages you voluntarily submit via the in-app feedback form You provide when submitting feedback
Peer-sharing data If you generate a share code, your workout history and progress may be visible to anyone who enters that code. You control this at all times. Only if you generate and distribute a share code
Subscription & purchase data Subscription status (active / expired / trial), purchase history, and entitlement records. Used to unlock Spotter Pro features and restore your subscription on reinstall. Managed via Apple App Store and RevenueCat; we do not store payment card details. Only if you start a free trial or purchase a Spotter Pro subscription

3. How We Use Your Data

4. Data Sharing & Third-Party Processors

We do not sell, rent, or trade your personal data. We share data only with the following service providers, each of whom processes data solely to provide their service:

ProviderPurposeData shared
SupabaseAuthentication, database, cloud storageAccount data, profile, all fitness/nutrition/coaching records
AI Provider (via our secure proxy)Generate coaching responses, food recognition, InBody parsingChat messages, exercise summaries, meal photos/text, InBody photos
Apple Inc.Payment processing for Spotter Pro subscriptions (App Store)Purchase transaction data, subscription status โ€” managed entirely by Apple; we do not receive raw payment card details
RevenueCatSubscription management and receipt verificationAnonymous user ID (your Supabase account ID), purchase records, subscription status, device platform data. RevenueCat does not receive your name, email, or workout data.
PostHogUsage analyticsAnonymised event data (no raw personal data fields)
SentryCrash reportingDevice info, OS version, error stack traces
Open Food FactsBarcode lookup, when you scan a packaged foodThe barcode number only. No account or personal data is sent.
Apple Inc.Checking whether a newer app version is availableA version lookup for the app. No account or personal data is sent.

Our AI proxy server strips identifying information before forwarding requests to the AI provider. AI provider keys are stored server-side and are never shipped in the app binary.

5. Data Security

6. Data Retention

7. Hong Kong PDPO โ€” Your Rights

Under the Personal Data (Privacy) Ordinance (Cap. 486), you have the right to:

To exercise these rights, use the in-app features (Profile โ†’ Edit Profile; ๆˆ‘็š„ โ†’ ๅˆช้™คๅธณๆˆถ) or contact us at support@spotterhk.com. We will respond within 40 days as required by the PDPO.

๐Ÿ—‘๏ธ Account deletion: Go to ๆˆ‘็š„ (Profile) โ†’ ๅˆช้™คๅธณๆˆถ (Delete Account) in the app and type the confirmation word shown on screen. This immediately and irreversibly removes your account and all associated data from our servers.

7A. If You Live Outside Hong Kong

Spotter is run from Hong Kong and is available in other countries. Your data is stored and processed by the providers listed in section 4, which may be located outside your country, including in the United States. By using Spotter you understand that your data will be transferred there.

European Economic Area, United Kingdom and Switzerland. We process your data on these bases:

You have the right to access, correct, delete, restrict or object to processing of your data, to receive a copy in a portable format, and to complain to your local data protection authority. We will respond within one month.

California and other US states. We do not sell your personal data or share it for targeted advertising. You may ask to know, correct or delete the personal data we hold about you, and we will not treat you differently for doing so.

Contact support@spotterhk.com for any of these requests. Calorie and nutrition figures in Spotter are estimates for general information and are not medical advice.

8. Apple HealthKit

If you grant permission, Spotter reads step count and heart-rate data from Apple HealthKit. This data is displayed on your home screen only. It is not uploaded to our servers, shared with third parties, or used for advertising. We do not write any data back to HealthKit. You can revoke this permission at any time in iPhone Settings โ†’ Privacy & Security โ†’ Health โ†’ Spotter.

9. Children

Spotter is not directed to children under 13, or under 16 in the European Economic Area and the United Kingdom, or the minimum age in your jurisdiction if higher. We do not knowingly collect personal data from children below these ages. If you believe a child has provided us with personal data, please contact us and we will delete it promptly.

10. Changes to This Policy

We may update this policy from time to time. We will revise the "Last updated" date above. Continued use of the app after changes are posted constitutes acceptance of the updated policy.

11. Contact

For privacy enquiries, data access or correction requests, or account deletion assistance:

Email: support@spotterhk.com
Website: spotterhk.com