Privacy Policy

1. Introduction

This Privacy Policy explains how PRODUCTX, K.K. ("we", "us") handles your information in the PINPLATE iPhone app and on the website pinplate.app (together, the "Service").

PINPLATE stores your records on your iPhone. You can use every logging feature without signing in. Your records reach our servers only when you sign in with Apple and start syncing to the cloud.

• We do not show ads. We do not ask for permission to track you for advertising (App Tracking Transparency).
• We do not sell your information.
• We do not use Health (HealthKit) data for advertising or sell it.
• PINPLATE does not send you notification or marketing emails (we only reply to your inquiries).

2. Who we are and how to contact us

Item	Details
Operator	PRODUCTX, K.K.
Representative	Kenta Ueno
Address	Miyamasuzaka Building 609, 2-19-15 Shibuya, Shibuya-ku, Tokyo 150-0002, Japan
Phone	+81-90-2173-7244
Contact	dev@productx.jp

We are the "controller" under the EU General Data Protection Regulation (GDPR) and the UK GDPR, and a "business operator handling personal information" under Japan's Act on the Protection of Personal Information (APPI).

3. Information we handle

3.1 Information that stays on your iPhone

The following is processed only on your iPhone and is never sent to us or anyone else.

Information	How it is handled
Voice	When you log by voice, the audio, its transcript and the interpreted result are processed on your iPhone. They are neither stored nor sent.
Camera	When you scan a machine's nameplate, the image is discarded after the text is read on your iPhone. It is not saved to your photo library.
Device settings	Appearance, haptics, sound effects, voice read-back, keep screen on, microphone, and voice logging language.
All data while you are not signed in	The records and profile described in 3.2 also stay only on your iPhone while you are not signed in (except the purchase, analytics and technical information in 3.4–3.6, and, if you consent, sending the items in 6.2 to external AI; data may be sent to Apple Private Cloud Compute even without signing in).

Only in the test version (TestFlight), if you consent, the app can save captured audio, transcripts and interpreted results on your iPhone so you can export them. They do not leave your device unless you export and share them yourself. This feature does not exist in the App Store version.

3.2 Information synced to the cloud when you sign in

When you sign in with Apple, we store the following in our cloud (Google Cloud / Firebase) and sync it between iPhones signed in to the same account.

Category	Main contents
Account	Firebase user ID, the user identifier issued by Apple, creation date, language and region, unit setting. We do not receive your name or email address.
Records	Workouts (start and end time, gym name, exercises, machines, weight, reps, effort, how each set was logged), routines, My Gym (gyms, machines, weight increment settings), machines you added yourself
Profile	Goal physique, training frequency, weak areas, age band (13–17 / 18 or older) and how it was obtained
Body data (handled as sensitive information)	Height, weight, areas to avoid (joints). Stored only if you consent (5.2).
Consents	Your consent status for sending data to external AI and for body data, the date and time of consent or withdrawal, and the version of the explanation you agreed to
AI text	Post-workout comments and weekly review text, the numbers of the research summaries cited, when and how each was created (on device, cloud, etc.)
Contributions to the common DB	Requests to add machines you created (created automatically when you add a machine; brand, model name, model number, movement, type, unit, increment; gym names are not included; while you are not signed in they are kept on this iPhone and sent when you sign in), increment reports (sent in a form that does not identify you), and machine error reports (selected fields and an optional note)
Subscription status	Your Pro entitlement status (written by our server based on your App Store purchase)

3.3 Health (HealthKit)

Only if you allow it, when you finish a workout we write a "Traditional Strength Training" workout (start and end time) to Health. We do not store Health data in iCloud as health information or send it to our servers. PINPLATE currently does not read any data from Health.

3.4 Purchase information

Pro is purchased through the App Store, and we never receive your payment details (such as card numbers). While you are signed in, to check your purchase status we receive your App Store purchase records (product, purchase, renewal and expiration dates, transaction identifiers) from Apple and store them linked to your account using Cloud Functions (7). When you purchase, we pass Apple an identifier derived from your account (a string that does not identify you personally) to link the purchase to your account. While you are not signed in, your purchase status is checked only on your iPhone and is not sent to us.

3.5 Usage analytics and crash reports

If you consent to usage analytics (5.3), we send the following to Google (Firebase Analytics and Crashlytics) to improve the app.

• Usage statistics: events such as screen actions and completed workouts, with their attributes (for example, number of sets, how sets were logged, where the paywall was shown)
• Crash reports: the circumstances of an abnormal termination (device model, OS version, app version, error details)
• Identifier: an identifier issued per app installation

We do not send: your name, text you type freely (gym names, machine names, notes, etc.), body data, audio, precise location, or advertising identifiers.

Under the same consent, the app receives configuration values we distribute (such as turning features on or off) from Firebase Remote Config. Without consent, it does not receive them and runs with default settings.

3.6 Other technical information

• Abuse prevention: when the app connects to our servers, we use Apple App Attest and Firebase App Check to confirm the request comes from the genuine app. Information used to verify the device is processed by Apple and Google.
• Connection logs: when the app connects to a server, connection data such as IP address, time and device type is processed temporarily on each provider's servers.
• Age check: on devices that support Apple's Declared Age Range, if you allow it, we receive only whether you are under 13, 13–17, or 18 or older. We do not receive your date of birth.
• Common machine DB updates: whether or not you are signed in, the app connects to Google Cloud Storage (for example at launch) and downloads a new version of the common DB if one is available. No information identifying you is sent.
• Checking the version of the Terms and Privacy Policy: whether or not you are signed in or have consented to analytics, the app connects to pinplate.app at launch to receive the current versions of the Terms of Use and Privacy Policy (to notify you of revisions). No information identifying you is sent. Connection data is processed temporarily on Vercel's servers.
• Sharing: personal-best sticker images are created on your iPhone. Sending them to Instagram or elsewhere is your own action, and once sent, the recipient service's policies apply.

3.7 Inquiries

If you email dev@productx.jp, we handle your email address, your name (if you include it) and the content of your inquiry to respond and keep a record. Emails are received and stored with Google LLC (Google Workspace)'s email service. We answer by replying to the email you sent us. Apart from replies, we never send you notification or marketing emails.

4. Purposes and legal bases

Purpose	Information used	Legal basis under the GDPR
To provide the Service, including logging, building menus, suggesting weights, history and charts	Records and profile in 3.1 and 3.2	Performance of a contract (Art. 6(1)(b))
To sync data between your signed-in iPhones and keep it when you change devices	3.2	Performance of a contract
To remove exercises that stress the areas you want to avoid, and to store height and weight as records	Body data	Explicit consent (Art. 9(2)(a))
To create detailed weekly reviews with external AI	Items in 6.2	Consent (Art. 6(1)(a))
To check your Pro entitlement, restore purchases and show subscription status	3.4	Performance of a contract
To add to and correct the common machine DB and to aggregate increment reports	Contributions to the common DB	Legitimate interests (Art. 6(1)(f): the accuracy of a DB used by all users)
To improve the app and fix bugs	3.5	EU, EEA, UK and Switzerland: consent (Art. 6(1)(a)). Other regions: legitimate interests (you can turn it off at any time in the Profile tab)
To prevent fraud and abuse and keep the Service secure	3.6, number of requests, prohibited-word checks	Legitimate interests
To keep records of consent changes and account deletions (in a form that does not identify you)	Dates and times of consents and deletion	Compliance with legal obligations and our legitimate interest in demonstrating compliance
To respond to inquiries	3.7	Legitimate interests or performance of a contract

We do not use your information for any other purpose. If we change a purpose, we will update this policy and, where required, ask for your consent again (14).

For the APPI, the purposes of use are those in the "Purpose" column above.

5. Consents

PINPLATE asks for your consent before handling the following three. Every logging feature works even if you do not consent to any of them. You can withdraw each one at any time in the Privacy section of the Profile tab.

5.1 Sending data to external AI

This is your consent to send the items in 6.2 when a detailed weekly review is created with Apple's or Google's AI. We ask on a screen that shows what is sent and where, the first time you create a detailed weekly review (or when you turn the consent on in the Profile tab). A single consent covers sending to both Apple and Google.

• Only people aged 18 or older are eligible. We do not ask people aged 13–17, and nothing is sent to external AI for them.
• After you withdraw, nothing more is sent. Text created before you withdrew remains readable. Requests already sent cannot be recalled.
• If what we send or where we send it changes, we will ask you again.

5.2 Body data (handled as sensitive information)

This is your consent to store your height, weight and areas to avoid (neck, shoulders, elbows, wrists, lower back, hips, knees, ankles). We ask the first time you save them.

• Areas to avoid are used to remove exercises that put stress on them from your menu. Height and weight are only stored as records, displayed and included in exports; they are not used for menu suggestions or AI.
• They are stored only on your iPhone and, if you are signed in, in your cloud. They are never sent to external AI, and they are not sent for analytics.
• If you withdraw, we delete your height, weight and areas to avoid from your iPhone and, if you are signed in, from the cloud at the next sync. Your menus will no longer exclude those areas (exercises already swapped are not changed back). We cannot delete anything outside the device, such as files you exported.
• There is no field for the reason you want to avoid an area. Please do not enter information about injuries or illnesses.

This information may not always qualify as "special care-required personal information" under the APPI or "data concerning health" under GDPR Art. 9, but PINPLATE handles it to that standard to be careful.

5.3 Usage analytics

This is your consent to send the analytics and crash reports in 3.5 and to receive configuration values.

• On iPhones with a region setting in an EU member state, the EEA (Iceland, Liechtenstein, Norway), the UK or Switzerland, we ask at first launch and send nothing until you consent.
• In other regions, sending is on by default. You can turn it off at any time with "Usage Analytics" in the Profile tab.
• When you turn it off, nothing more is sent. Data already sent is deleted when you delete your account, at which point we ask Google to delete it (9).

6. AI features

6.1 Where the AI runs

PINPLATE's AI text (post-workout comments and weekly reviews) is created with the first available option below.

Method	Conditions	Sent outside the device
On-device model (Apple Foundation Models)	iPhone that supports Apple Intelligence	No
Apple Private Cloud Compute	18 or older, supported iPhone and region on iOS 27 or later, consent to external AI, within the daily limit	Yes (Apple)
Google Gemini (via our server)	18 or older, the two options above are unavailable, consent to external AI, signed in, Pro (the first review is free), within the monthly limit	Yes (Google)
Templates	None of the above is available	No

Post-workout comments are created only by the on-device model or templates and are never sent outside the device.

6.2 What is and is not sent to external AI

Sent	Not sent
Age band (that you are 18 or older)	Height, weight, areas to avoid, weak areas
Goal physique	Audio
Totals by body part and exercise (exercise names, brand and model names of machines in the common DB, changes in sets, weight and reps)	Gym names and other text you type freely, such as notes
Progression status (suggested changes to weight, reps or sets and the type of reason)	Names of machines you added yourself that we have not yet reviewed (replaced with the exercise name)
Candidate numbers of research summaries (evidence cards), which are not your information	Information that identifies you (Apple identifier, Firebase user ID, name, email address, etc.)

• Apple Private Cloud Compute: sent directly from your iPhone. No sign-in is required. Apple states that what is sent is used only to create the response.
• Google Gemini: sent via our server (Cloud Functions on Google Cloud). After using your account to check your Pro entitlement and monthly limit, the server removes information that identifies your account, attaches a number used only for that request, and sends it to the Gemini API. Apart from saving the response to your cloud as your weekly review and keeping a count of requests to enforce limits, we do not store what was sent.
• Handling by the recipients follows their terms: Apple Privacy Policy, Gemini API Additional Terms of Service.

6.3 AI labels and limitations

• Text created by AI is labeled "Created by AI" (EU AI Act, Art. 50). Templates are not labeled.
• Weights and set counts are not decided by AI. AI explains the results calculated by PINPLATE's rules.
• AI text is not medical advice (Terms of Use).

7. Service providers and sharing

We use the following providers to process information so the Service can run. We have data processing agreements (DPAs) with each, and they process information only on our instructions.

Provider	Country	Services used	Information handled
Google LLC	United States	Firebase Authentication, Cloud Firestore, Cloud Functions, Cloud Storage, App Check, Remote Config	Cloud data in 3.2, purchase information in 3.4 (when signed in), technical information in 3.6
Google LLC	United States	Firebase Analytics, Crashlytics	3.5 (only with consent)
Google LLC	United States	Gemini API	Items sent in 6.2 (only for consenting users aged 18 or older)
Vercel Inc.	United States	Website hosting and visit measurement	13, and the version-check connection in 3.6
Google LLC (Google Workspace)	United States	Receiving, storing and replying to inquiry emails (dev@productx.jp)	3.7

Our relationship with Apple Inc. (United States) is as follows.

• App Store, Sign in with Apple, Health and Declared Age Range: Apple handles information under its own terms and privacy policy. We receive only what this policy describes (purchase status, user identifier, age band, etc.).
• Private Cloud Compute: used, as described in 6.2, to create weekly reviews for consenting users aged 18 or older.

Except where required by law, we do not share your information with third parties for any other purpose.

8. International transfers

Cloud data is stored in a Google Cloud region in the United States (nam5). The providers in 7 also mainly process information in the United States (inquiry emails are processed in Google LLC (Google Workspace)'s country and elsewhere).

• Transfers from the EU, EEA, UK and Switzerland: based on the European Commission's Standard Contractual Clauses (SCCs) and, for the UK and Switzerland, their respective addenda. Where a provider is certified under the EU-U.S. Data Privacy Framework, that certification is also a basis.
• Transfers from Japan (APPI Art. 28): the destination is the United States. The United States has no comprehensive federal privacy law; there are state laws such as the California Consumer Privacy Act. Each provider has committed in its data processing agreement to measures that protect personal information. For information on the U.S. system, see the Personal Information Protection Commission's materials (in Japanese).
• Transfers from Korea and Brazil: the items required by each country's law are set out in 15.

9. How long we keep information

Information	Retention
Data on your iPhone	Until you delete the app, use "Erase Data on This iPhone", delete your account, or sign out and erase data
Cloud data	While your account exists. When you delete an individual item (such as a record), it is marked as deleted so other iPhones learn of the deletion, and permanently removed after 30 days
Cloud data when you delete your account	Deleted immediately, without waiting 30 days
Backups	Created daily for disaster recovery and deleted after 30 days. After you delete your account, your data may remain in backups for up to 30 days
Purchase information (the link between purchases and your account)	While your account exists. Deleted immediately when you delete your account (the App Store purchase records themselves are kept by Apple)
Analytics data	14 months. When you delete your account, we request deletion, completed within 30 days
Crash reports	90 days
Machine requests	Content is kept for the common DB. When you delete your account, the link to you is removed so it no longer identifies you
Machine error reports	Content is kept to review and correct the DB. When you delete your account, the link to you is removed
Increment reports	Received in a form that does not identify you and kept for aggregation (because they are not linked to you, they are not covered by account deletion)
Records of consent changes and account deletions	In a form that does not identify you, for 3 years
Inquiry emails	3 years after the inquiry is closed
Workouts written to Health	Remain on your iPhone as Health data. Use the Health app to delete them
Purchase and analytics information of users who are not signed in	Even after "Erase Data on This iPhone", analytics data already sent remains (the analytics identifier is reset, so later analytics are not linked to earlier use). Analytics data is deleted after the period above. Purchase records are not sent to us and remain with Apple's App Store (you can restore purchases with the same Apple Account)

9.1 What remains after you delete your account

When you delete your account, your records, profile, body data, consents and AI text in the cloud and on that iPhone are all deleted. Only the following remain in a form that does not identify you, are deleted after a set period, or remain where we cannot reach them.

• The content of machine requests and error reports you sent (unlinked from you and kept for the common DB)
• Increment reports (received from the start in a form that does not identify you)
• Records on another iPhone that was signed in to the same account (they remain on that iPhone until you use "Erase Data on This iPhone" there or delete the app)
• Records of consent changes and account deletion (in a form that does not identify you)
• Backups (deleted after 30 days)
• Analytics data (deletion requested and completed within 30 days)
• App Store purchase records (kept by Apple)
• Workouts written to Health (remain on your iPhone as Health data)

Deleting your account does not cancel your App Store subscription (Terms of Use, Article 6).

10. Security measures

• All communication is encrypted (TLS). Data stored on servers is encrypted by Google.
• Data on your iPhone is protected by iOS file protection.
• Cloud data is restricted so that only you can read and write it.
• App Check blocks requests from unauthorized apps. Secret keys are kept on the server, not embedded in the app.
• What we send to external AI is in a form that does not identify you.
• Administrative accounts are protected with two-factor authentication, and access is limited to those who need it.

11. Your rights and how to exercise them

Right	How
Get your data (access and portability)	In Profile > Account > "Export Data", you can export your set records as CSV, or all your data, including profile, body data, consent status, AI text and machine requests, as JSON. Available to guests and free users
Correct your data (rectification)	Edit records, profile and body data in the app
Delete your data (erasure)	If signed in: Profile > Account > "Delete Account". This deletes your cloud and iPhone data and asks the providers to delete purchase and analytics data. If not signed in: "Erase Data on This iPhone"
Withdraw consent	The switches in Profile > Privacy (5)
Restrict or object to processing	Contact dev@productx.jp
Lodge a complaint	You can complain to the data protection authority where you live (the supervisory authority in each EU/EEA country, the UK ICO, etc.). In Japan, you can also use the consultation service of the Personal Information Protection Commission

For requests you cannot complete in the app (such as access to analytics data), contact dev@productx.jp. We generally respond within one month. Because the app does not hold your name or email address, we may ask for information shown in the app to verify that the request is yours. There is no fee.

If you lost or gave away your iPhone and cannot delete your account by signing in with the same Apple ID on another iPhone, ask us to delete it at dev@productx.jp. We will explain how we verify that the request is yours and then delete the account (the steps are described on the Support page). Because we cannot remove the link with Apple ourselves, our reply will explain how to stop using Sign in with Apple for PINPLATE in your iPhone or Mac settings.

12. Age

• PINPLATE is not available to anyone under 13. We check your age band at first launch, and you cannot proceed if you are under 13. Once we learn you are under 13, analytics information held on the device up to that point is discarded without being sent.
• People aged 13–17 can use every logging feature. External AI (Apple Private Cloud Compute and Google Gemini) is not used for them; AI text is created only by the on-device model or templates. No advice about physique or weight loss is shown.
• Some countries set an age below which a parent's consent is required for consents such as body data and analytics.
• If you learn that we have received information from a child under 13, please contact dev@productx.jp. We will delete it promptly.

13. Website (pinplate.app)

• The website is hosted on Vercel.
• We measure visits with Vercel Web Analytics. It does not use cookies. It aggregates page views; the number of clicks on the App Store badge, the language switcher and the email link; and referring sites, countries and device types. Visitors are counted without cookies, using a value valid only for that day. It does not identify individuals or track them across other sites.
• To deliver the website, connection data such as IP addresses is processed temporarily on Vercel's servers.
• The website does not collect information through forms.

14. Changes to this policy

• We may update this policy to reflect changes in law or the Service. When we do, we will update the last-updated date and version on this page and describe the changes here.
• For changes that narrow your rights, or that change what is sent to external AI, where it is sent, or how body data is used, we will give notice on this page before they take effect, and also on the Home screen the next time you open the app after the revised version is published. During the notice period, this page shows the version in force; the revised version is placed on its own version page before the effective date and linked from this page. Where required, we will ask for your consent again in the app and will not apply the new handling until you consent.
• Earlier versions can be read from the version numbers in the revision history at the end of this page.

14.1 Language

This policy is written in Japanese, and translations into English and other languages are provided. If a translation differs in meaning from the Japanese version, the Japanese version prevails, unless the laws of the country where you live provide otherwise.

15. Additional information by region

15.1 Japan (APPI)

• Requests for disclosure, correction, suspension of use, etc. of retained personal data are accepted as described in 11.
• The security measures we take are described in 10.
• Complaints and consultations: dev@productx.jp

15.2 EU, EEA, UK and Switzerland

• Your rights under the GDPR, the UK GDPR and the Swiss Federal Act on Data Protection are described in 11.
• We do not make decisions based solely on automated processing that produce legal effects or similarly significant effects on you (AI text explains menu suggestions, and you decide whether to use them).

15.3 Korea

The items required by the Personal Information Protection Act for overseas transfers (recipient, country, date, time and method of transfer, items, purposes and retention periods) are set out in 7, 8 and 9. Transfers take place over the network when you use the Service.

15.4 Brazil

You can exercise your rights under the LGPD (General Data Protection Law) as described in 11.

16. Contact

For questions about this policy or how we handle information, email dev@productx.jp.

PRODUCTX, K.K. Miyamasuzaka Building 609, 2-19-15 Shibuya, Shibuya-ku, Tokyo 150-0002, Japan

Revision history

Version	Effective date	Changes
0.9	December 20, 2026	First version