Spodi Privacy Policy

Effective date: October 13, 2026

This Privacy Policy explains how Spodi collects, uses, and protects your personal data when you use the website spodi.ru, its web app, and the Spodi app for iOS (the "Service").

This Policy is not a consent to personal data processing. The data needed to run the Service is processed on the basis of your contract with us — the Terms of Service and the Offer (Article 6(1)(5) of Federal Law 152-FZ). Where the law requires separate consent — newsletters, analytics cookies, sharing data with your coach, health information you share with the AI Coach or from the Health app (Apple Health) — we ask for it separately: with a checkbox at registration, in settings, on your first message to the AI Coach or when you connect Apple Health, through the cookie banner (Section 7), or by accepting a coach invitation. The newsletter consent text is at spodi.ru/en/consent.

Data Controller

Individual Entrepreneur Gulyaev Maksim Yuryevich
OGRNIP: 326527500032500
INN: 524613147662
Address: 606440, Russia, Nizhny Novgorod region, Bor
Data privacy contact: privacy@spodi.ru
General support: support@spodi.ru

1. Data We Collect

Category	Data	Purpose
Account and contact	Name, email, phone if it was provided earlier, password hash, two-factor secret	Creating an account, signing in, recovering access, service notices. Registration and ordinary sign-in by phone number are not offered in the current version of the Service
Profile	Avatar, gender, date of birth, height, body weight	Personalization and calculating workout metrics
Settings	Time zone, language, units, interface and timer settings, notification settings	Running the Service the way you set it up
Recommendation inputs	Goals, experience, available equipment, training days, results of generated recommendations	Selecting workouts and exercises. The workout generator runs on the Operator's own servers; for AI Coach answers this data, together with your workout history, is passed to Cloud.ru (Section 4)
Workout data	Exercises, sets, weight, duration, notes, body weight	Core functionality
Media	Set videos you record and their poster frames	Reviewing your technique in the app. The Operator does not use these recordings to establish identity, so they are not biometric personal data under Article 11 of Federal Law 152-FZ
Notifications	Device token, web push subscription endpoint, delivery and open status, the text of the notification sent	Delivering notifications to your device
Subscription and payments	Plan, orders, amounts, payment statuses, links to receipts	Taking out and performing the subscription, meeting the Operator's obligations
Export	Generated export files and records of export requests	Providing your data at your request
AI Coach conversations	Your messages and the AI Coach's answers, suggested workouts and programs, answer ratings (like, dislike, reason, comment) and, on a dislike, a snapshot of that answer's context	Answering questions about training, selecting workouts and programs based on your profile and workout history, improving the AI Coach
Coach interaction	Coach-client link, sharing settings, assignments, comments, plan adherence metrics	Running coach mode
Technical	IP address, device type, cookies	Service operation, security, traffic analytics
Auth providers	External IDs: VK ID and Yandex ID for signing in; Apple ID and Telegram only to confirm your identity when migrating an account created earlier	Sign-in and account recovery

Data sources: provided by you during registration and service usage, received from connected authentication providers (your choice), and collected automatically from your device and browser.

Health information.How you feel, pain, injuries, pregnancy and symptoms during training that you yourself tell the AI Coach are health information (Article 10 of Federal Law 152-FZ). It is processed only with your separate consent (Section 3) and only to answer you in the chat and to choose a safe load. Sharing such information is optional, including when answering the AI Coach's follow-up questions about how you feel, pain or injuries. Such information is not used for any other purpose.

Apple Health.In the iOS app you can connect the Health app (Apple Health). With your permission the Service then reads workouts, active energy, weight, height, body fat percentage, lean body mass, waist circumference, heart rate, date of birth and sex, nutrition (calories, protein, fat, carbohydrates, water) and recovery (resting heart rate, heart rate variability, sleep, steps) from it, and writes workouts (with distance for cardio), active energy, weight and height from the Service to it. You choose which of these to share in the iOS access sheet and can change it in the Health app settings. This data is health information: it is processed only with the same separate consent (Section 3), to keep track of workouts and body measurements and to choose a training load; it is not shared with third parties other than Cloud.ru for the AI Coach's replies, and it is not used for advertising. When you disconnect Apple Health in the Service or withdraw the consent, it is deleted from the Operator's servers.

2. How We Use Your Data

Providing Service functionality
Account management
Authentication
Cross-device sync
Workout notifications (configurable in the Service settings)
Running the AI Coach: answering questions about training and recovery, selecting workouts and programs
Marketing communications (with separate consent)
Improving the Service
Security and fraud prevention
Legal compliance

3. Legal Basis

Contract performance (Article 6(1)(5) of Federal Law 152-FZ) — account, profile, workouts, videos, subscription and payments, export, workout notifications, coach mode, AI Coach conversations (except health information), and technical data (IP address, device type, session cookies) for the availability and security of the Service: everything needed to run the Service as described in the Terms of Service and the Offer.
Consent of the data subject (Article 6(1)(1) of Federal Law 152-FZ) — newsletters (a separate checkbox at registration or in settings), analytics cookies (Section 7), sharing data with the coach you choose (accepting an invitation).
Consent to processing of health information (Article 10(2)(1) of Federal Law 152-FZ) — health information you share with the AI Coach or that comes from the Health app (Apple Health): a separate checkbox on your first message to the AI Coach or when you connect Apple Health.

Processing methods: collection, recording, systematization, accumulation, storage, clarification (update/change), retrieval, use, transfer (provision/access), depersonalization, blocking, deletion, and destruction of personal data. Processing is performed both with and without automation tools.

4. Data Sharing

We do not sell your data. We share with:

Yandex Cloud (Russia) — hosting and storage
Yandex Object Storage (Russia) — storage of avatars and set videos
Yandex Postbox (Russia) — email delivery: service emails and, with your consent, newsletters
Yandex Metrica (Russia) — anonymised traffic statistics of the Service, with your consent (see Section 7)
Cloud.ru (Cloud Technologies LLC, Russia) — running the AI Coach: chat messages and context (gender, age, height, body weight, goals, questionnaire, workout history and, with Apple Health connected, a summary of Health app data) are processed by language models hosted on servers in Russia, on the Operator's instructions. Cloud.ru does not use this data to train models
VK ID / Yandex ID — signing in (your choice)
Apple ID / Telegram — confirming your identity when migrating an account created earlier. The link to the previous provider stays on the account after migration, so that a returning user is recognised instead of getting a second, empty account
The coach you choose — your name and avatar, workout history, exercises, sets, statistics, records, workout and exercise notes, once you accept the invitation and only while the link is active. Set notes and videos only when you switch that sharing on separately. Sharing stops when you revoke access
Apple Push Notification service, your browser's push service — delivering notifications, if you turned them on

Cross-border transfer

Personal data is processed and stored in the Russian Federation. A cross-border transfer occurs only when notifications are delivered, and only if you turned them on: the device token or browser subscription endpoint, an internal delivery identifier, and the notification text are passed to the delivery service (Apple Push Notification service for the iOS app; your browser's push service for the web version). The notification text may contain a coach's name or the name of a generated export file.

You can turn notifications off in the Service settings; the transfer stops when you do. No other category of personal data leaves the Russian Federation.

5. Storage and Security

Data stored in the Russian Federation (Yandex Cloud)
HTTPS/TLS, bcrypt passwords, AES-256-GCM for 2FA secrets
After you delete your account, the data needed to provide the Service — including videos and poster frames — is kept in a restricted mode and erased within 30 days at the latest
Payment records are kept separately, in the minimum necessary form, for the retention period that tax law prescribes for accounting documents. They are not used to provide the Service, to personalize it, or for marketing
AI Coach conversations are kept until you delete the chat or your account; a deleted chat is erased together with its messages and ratings after 90 days. The context snapshot saved with a dislike is erased after 180 days; the rating itself stays in the chat

6. Your Rights

You have the right to:

be informed about how your personal data is processed;
access your personal data;
request corrections;
request deletion (via the Service settings or support);
withdraw consent: to the newsletter — in the Service settings (notifications) or by writing to privacy@spodi.ru; to analytics cookies — with the “Decline” button in the banner or via “Cookie settings” in the site footer; to sharing data with a coach — by unlinking the coach in the Service settings; to processing of health information — in the AI Coach settings, in the Apple Health section or by writing to privacy@spodi.ru (the AI Coach chat then becomes unavailable, the conversation is destroyed after 90 days and data from the Health app is deleted immediately; consent text — spodi.ru/en/health-consent);
delete your account — in the Service settings or via support;
lodge a complaint about the Operator with Roskomnadzor or in court.

This English text is a translation of the Russian original. If the two differ, the Russian version applies. This does not limit any right granted to you by mandatory provisions of applicable law.

7. Cookies

The Service uses cookies for the following purposes:

Sign-in session (required) — keeps you signed in;
Language preference (required) — remembers the interface language you chose;
Basic traffic analytics (Yandex Metrica) — anonymised usage statistics to improve the Service;
Session recording (Webvisor) and click maps — only with your separate consent.

By using the Service you consent to the collection and analysis of cookies for anonymised traffic statistics. This data is not used to identify you. Decline in the banner: from that moment the counter receives no page transitions, and on the next page load it is not loaded at all. You can change your mind at any time through the “Cookie settings” link in the site footer. Session recording and click maps stay off until you consent.

8. Changes

The Operator may amend this Policy. A new revision is published at spodi.ru/privacy and applies from the effective date stated in it.

The Operator notifies you of material changes through the Service (a push notification or an in-app banner) before they take effect.

9. Contact

Data privacy: privacy@spodi.ru

General support: support@spodi.ru

10. Data Subject Request Handling

You can submit a request to privacy@spodi.ruwith the subject line "Data Subject Request".

Response time: up to 10 business days from receipt of the request
The term may be extended by up to 5 business days with prior notice to the requester
We may request additional information to verify the requester's identity