Privacy Policy

Last updated: 23 September 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. If you sign in through a third-party provider, we receive the basic profile details you agree to share.

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.

Transaction data: your credit balance and ledger, and records of purchases and refunds.

Technical and usage data: device and browser information, IP address, approximate location derived from it, log data, and — if you accept analytics cookies — basic usage analytics.

Support data: the messages and details you send us when you contact support.

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, where you have not opted out, send service and (if you consent) occasional product messages.

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 (for non-essential cookies and any optional marketing, which you can withdraw at any time); 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.

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, bank details for payouts, 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. We use this to decide on your application, to verify your identity and eligibility (including sanctions checks) before approval and before paying you, to pay your withdrawals into your bank account, 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 and then as long as we need it to meet legal and accounting obligations. 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. Bank details and payout records are kept as financial records for as long as the law requires. 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, AI model providers, analytics (where you consent) and payment providers — each acting under contract on our instructions. 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 remove your personal data from the live service within 30 days, except records we must retain for legal or accounting reasons — for example, purchase and accounting records, which we keep for as long as Estonian accounting law requires (generally seven years). Backups are overwritten on our normal cycle.

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 consent for cookies or marketing 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 use a small number of cookies and similar storage, as described in our Cookie Policy. You can accept or decline non-essential cookies from the banner or by opening Manage Cookies at any time.

14. Children

The service is not directed at children under 16, and we do not knowingly collect their personal data. 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.