Privacy Policy
Last updated: 12 November 2026
This policy explains what personal data Dexaro kj OÜ collects when you use FormTune, how and why we use it, who we share it with, and the rights you have over it under the EU General Data Protection Regulation (GDPR) and the Estonian Personal Data Protection Act. It applies to the FormTune website at formtune.app and its app.
1. Data controller
Dexaro kj OÜ (registry code 17547926), registered in Estonia with its registered address at Hooldekodu tee 23a-48, 13914 Tallinn, Harju maakond, Estonia, is the data controller responsible for your personal data. For any privacy question or to exercise your rights, email privacy@formtune.app.
2. What we collect
Account data: your email address and a hashed version of your password.
Coaching profile answers: what you tell us when you set up a profile — discipline, movement, experience level, goal, music preference and, only if you choose to answer, an age range, how often you train and your sex (each can be left blank or answered “Prefer not to say”). We use them only to tailor your feedback.
Coach application data, if you apply to work as a coach: see “If you apply to be a coach” below.
Content you submit: the media (such as images or video) and text you upload or describe for coaching, and the AI results we generate for you. If you use the live voice coach, your speech is streamed to our voice provider to run the conversation.
Telegram data, if you link the Telegram bot: your Telegram chat ID, the clips and messages you send the bot, and where you are in the bot's step-by-step flow.
Transaction data: your credit balance and ledger, and records of purchases and refunds (pack, credits, amount and currency charged, the payment reference and its status). We do not store your card number or security code.
Technical data: device and browser information, IP address, the country derived from it (used to apply the sanctions restrictions in our Terms) and server log data. We do not run analytics or advertising trackers.
Support data: the messages and details you send us by email or through the contact form.
3. How we use your data
To create and run your account and provide the coaching service.
To generate your results, including sending your submitted content to AI providers acting as our processors.
To process credit purchases and refunds and keep accurate transaction records.
To keep your history and credit ledger available to you.
To secure the service, prevent fraud and abuse, and debug problems.
To respond to your support requests and to send service emails: a welcome email when you sign up, a receipt for each purchase and password-reset links. We do not send marketing email.
To comply with our legal and accounting obligations. We do not sell your personal data, and we do not use your submitted content to train third-party AI models for their own purposes.
4. Legal bases
We rely on: performance of our contract with you (to run the service and process your purchases); our legitimate interests (to secure and improve the service and prevent abuse, balanced against your rights); your consent, where we ask for it (for example, the optional profile answers, which you can remove at any time by editing your profile); and compliance with a legal obligation (for example, keeping required financial records).
5. AI processing
To generate results we may send your submitted content to AI model providers who act as our processors. They process it only to return a result to us and under contractual confidentiality and data-protection terms, and they are not permitted to use your content for their own purposes. A current list of the AI and infrastructure providers we use is available on request from privacy@formtune.app.
Clips and generated images and audio are kept in our cloud file storage at long, randomly generated web addresses that are not listed or searchable. Anyone who had the exact address could open the file, so do not share those links if you want a clip kept private. They are deleted when you delete your account.
6. When you hire a fitness coach
If you hire one of our fitness coaches, the coach who accepts your request can see what you shared for that request: your note, the times you offered and any clip you attached. They do not see your email address or payment details. Coaches are independent professionals bound by our Specialist Terms to use this only to do your request and to keep it confidential. We keep the request, the delivery and the related credit records with your account history.
7. If you apply to be a coach
When you apply to work as a coach we collect your name, country of residence, languages, years coaching, certifications, the disciplines and client levels you coach, how many clients you have coached, the services you will take, your weekly availability, timezone and usual turnaround, portfolio links, bio, a copy of a government-issued photo ID and, if you choose to add one, your CV, plus the date you accepted our Specialist Terms. Once approved, you add a payout card in your specialist console: the cardholder name, the card number and the expiry date (never the security code). The card number is stored encrypted and only its last four digits are ever shown; our staff can see the full number only to send a payout, and each time they do it is recorded. We use this to decide on your application, to verify your identity and eligibility (including sanctions checks) before approving you, to confirm them again before paying you if we need to, to pay your withdrawals to your payout card, and to keep the records the law requires. Our legal bases are taking steps to enter into a contract with you, our legitimate interest in preventing fraud, and compliance with our legal obligations.
Your ID document is stored privately in our database — never at a public web address — and can only be opened by our staff through an authenticated page. It is never shown to customers. Customers see only your display name, bio and languages.
Adding a CV to your application is optional (PDF or Word). If you add one, we use it only to assess your application. It is stored privately in our database in the same way as your ID document — never at a public web address — and can only be opened by the staff who review applications. It is never shown to customers.
We keep an ID document for as long as you are an approved coach. If your application is declined, we delete your ID document 90 days after the decision. An ID upload that is never attached to an application is deleted after one day. Deleting your account deletes your ID document, CV, application, payout card and any bank details you gave us before at once. Your earnings and withdrawal records (amounts, dates, status and the payout reference) are kept as financial records for as long as the law requires, without your name, email, card or bank details. A CV, if you added one, is kept and deleted on the same schedule as your ID document.
8. Who we share it with
We share personal data only with service providers who help us run the service — such as hosting and infrastructure, file storage, AI model and voice providers, our email provider, Telegram (if you link the bot) and our payment processor — each acting under contract on our instructions. When you pay by card, the payment processor receives your card details, the name on the card, any billing address you enter, your email address and your IP address, to take the payment and check it for fraud. We may also share data where required by law, to enforce our terms, or in connection with a business reorganisation, always with appropriate safeguards. We do not sell your data.
9. International transfers
Some of our providers may process data in other countries. Where they do, we rely on appropriate safeguards — such as recognised legal protections and contractual commitments — so that your data receives an equivalent level of protection. You can ask us for details of the safeguards we use.
10. Retention
We keep your account and history for as long as your account is open. When you delete your account, we delete your profile, sessions, results, the clips and generated files in our file storage, and your Telegram bot state straight away, and remove anything left in backups within 30 days. We keep, without your name, email, card or bank details, with a one-way reference in place of your account: your purchase records, your credit ledger (amounts, reasons and dates) and, if you worked as a coach, your earnings and withdrawal records, for as long as Estonian accounting law requires (generally seven years). We also keep your email address on a list of addresses that have already received the free welcome credits, so the same address cannot claim them again — it is not linked to anything else and is used for nothing else. Contact-form messages are kept so we can follow up, and you can ask us to delete them at any time.
11. Security
We use technical and organisational measures appropriate to the risk — including encryption in transit, hashed passwords, access controls and limiting who can access personal data — to protect your data. No system is completely secure, but we work to protect your information and to notify you and the relevant regulator of a serious breach where the law requires.
12. Your rights
Under applicable data protection law you can: access a copy of your data; correct inaccurate data; delete your data; export your data in a portable format; and object to or restrict certain processing. You can withdraw any consent you have given at any time. Use Settings to delete your account, or email privacy@formtune.app to make a request — we respond within one month. You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), our lead supervisory authority (www.aki.ee), or with the data protection authority in the EU country where you live or work.
13. Cookies
We set one sign-in cookie and one local-storage item that remembers your cookie-banner answer, both strictly necessary and both named in our Cookie Policy. We set no analytics or advertising cookies.
14. Children
The service is only for people aged 18 or over, and we do not knowingly collect personal data from anyone under 18. If you believe a child has given us personal data, contact us and we will delete it.
15. Changes to this policy
We may update this policy from time to time. The “Last updated” date above shows when we last did, and we will take reasonable steps to tell you about material changes.
16. Contact
Questions about this policy or how we handle your data? Email privacy@formtune.app.