Privacy Policy
Your privacy matters to us. This policy explains how we collect, use and protect your personal data when you use Tsemppi.
1. Data Controller
The controller responsible for processing your personal data is:
Tsemppi Fitness Oy
- Business ID: 3377898-6
- Address: Kolmas Linja 30 B, Helsinki, Finland
- Email: info@tsemppiapp.com
2. Data We Collect
We collect the following data to provide our service:
Basic information
Name, email address, date of birth, gender
Account data
Username, password (encrypted), profile picture
Workout data
Training history, performance records, weights, reps, progress data
Body data
Height, weight, physical limitations (optional)
Usage data
App usage patterns, device information, IP address
Note: We do not collect sensitive health data. Workout and body data are optional — you decide what to save.
3. AI & Data Processing
Tsemppi uses AI to generate personalized workout programs. Here is exactly how it works:
What data AI uses
- •Goal: Muscle gain, strength, fat loss or performance
- •Level: Beginner, intermediate or advanced
- •Frequency: How many days per week you want to train
- •Duration: Target time per session
- •Equipment: Gym, basic equipment or home workout
- •Limitations: Any injuries or restrictions (knee, shoulder, back, hip)
Third-party AI service
We use OpenAI's GPT-4o-mini model to generate workout programs. When you create a new program:
- •We send OpenAI only the onboarding data listed above — no personally identifiable information such as name or email
- •OpenAI does not use API data to train its models
- •Data is processed in accordance with GDPR
Data storage
- •All user data is stored on our own servers within the EU
- •Generated workout programs are saved to your account, not to OpenAI
- •Workout history and performance records are stored only in our own database
AI limitations: The AI generates a workout program based on the information you provide and our exercise library. AI does not replace professional advice — we recommend consulting a doctor before starting a new program, especially if you have health conditions.
4. App Permissions
Tsemppi may request the following permissions on your device. All permissions are optional and can be managed in your device settings:
Camera
OptionalUsed for taking a profile photo and saving workout videos and progress photos to your profile.
Notifications
OptionalUsed to remind you of workouts, notify you of community activity (likes, comments, followers) and support message replies.
HealthKit (iOS)
OptionalHealthKit integration allows syncing workout data with Apple Health so you can track all your activity in one place.
Note: The app works fully without these permissions. We only request access when you use the relevant feature for the first time.
5. How We Use Your Data
We use your data for the following purposes:
- ✓Generating personalized workout programs with AI
- ✓Tracking and visualizing your progress with a muscle map
- ✓Managing your user account and authentication
- ✓Providing community features (if you choose to share your workouts)
- ✓Improving and developing the service
- ✓Customer communication and support
6. Data Security
We protect your data carefully:
Encryption
All data is encrypted in transit (TLS) and at rest. Passwords are hashed using bcrypt.
Secure infrastructure
We use server infrastructure located within the EU (MongoDB Atlas).
Access control
JWT token-based authentication with 90-day session validity.
Regular audits
We review our security practices on a regular basis.
7. Data Sharing
We never sell your data
Your personal data is never sold to third parties for marketing purposes.
We share data only with:
- •OpenAI (GPT-4o-mini): Workout program generation — only onboarding data, no personal identifiers
- •Service providers: Cloud infrastructure (MongoDB Atlas, Sentry error tracking)
- •Community features: Other users only if you choose to share your workouts publicly
- •Legal obligations: Authorities only when required by law
8. Cookies & Analytics
We use cookies to ensure the service functions correctly:
Essential cookies
Login and session management — these cannot be disabled.
Analytics cookies
Help us understand how the app is used.
Performance cookies
Improve app speed and functionality.
You can manage cookie preferences in the app settings or through your browser.
9. Data Retention
- 👤Account data: Retained for as long as your account is active
- 💪Workout data: Retained for the lifetime of your account so you can track your progress
- 🗑️After account deletion: Data is permanently deleted within 30 days
- 📊Anonymized statistics: We may retain anonymized aggregate data for service improvement
- ⏰Session expiry: After 90 days of inactivity you will need to log in again
10. Your Rights (GDPR)
You have the following rights regarding your personal data:
Right to access
You can request a copy of all data we hold about you.
Right to rectification
You can correct inaccurate or incomplete information.
Right to erasure
You can delete your account from the app settings ("right to be forgotten").
Right to restrict processing
You can restrict how your data is processed in certain situations.
Right to data portability
You can receive your data in a machine-readable format.
Right to object
You can object to the processing of your data for marketing purposes.
To exercise your rights, email us at info@tsemppiapp.com. We will respond within 30 days.
11. Minors
Tsemppi is intended primarily for adult users. If you are under 16:
- •You require parental or guardian consent to use the service
- •A parent or guardian has the right to review and delete a minor's data
- •We do not knowingly collect data from children under 13
12. Changes to This Policy
We may update this privacy policy from time to time. We will notify you of significant changes via:
- 📱In-app notification
- 🌐Our website
We recommend checking this policy periodically. Continued use of the service after changes constitutes acceptance of the updated policy.
13. Right to Lodge a Complaint
If you believe that the processing of your personal data infringes data protection law, you have the right to lodge a complaint with a supervisory authority. In Finland, the competent authority is:
Office of the Data Protection Ombudsman (Finland)
- Address: Lintulahdenkuja 4, 00530 Helsinki, Finland
- Email: tietosuoja(at)om.fi
- Phone: +358 29 566 6700
- Website: tietosuoja.fi/en
You may also contact the data protection authority in your country of residence within the EU/EEA.
14. Contact Us
If you have questions about this privacy policy or wish to exercise your rights, please get in touch:
Kolmas Linja 30 B, Helsinki, Finland
Tsemppi Fitness Oy (Business ID: 3377898-6)