Do Not Sell or Share My Personal Information

1. Our Commitment

BOGERT CSN 443, LLC d/b/a Refactor Fitness ("Refactor Fitness", "we", "us", "our") does not sell, rent, trade, or otherwise transfer your personal information or your consumer health data to third parties in exchange for money or other valuable consideration. We also do not "share" your personal information for cross-context behavioral advertising as that term is defined under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, "CCPA"). This applies to every category of personal information we collect, including, without limitation:

• Account information (email address, name)
• Body measurements and health metrics
• Nutrition and dietary data, including allergies and restrictions
• Workout and exercise data
• Notes
• Injury, limitation, and AI conversation data
• App preferences and settings
• Subscription and purchase history
• Optional product analytics and crash diagnostics (Firebase, only with your consent)

For consumer health data specifically, the no-sale commitment is also stated in our Consumer Health Data Privacy Policy §5, in compliance with RCW 19.373.

2. Your California Privacy Rights

If you are a California resident, the CCPA gives you the following rights:

• Right to know what personal information we collect, the sources, the business purposes, and the categories of recipients.
• Right of access / data portability — receive a copy of the personal information we hold about you.
• Right to delete personal information we have collected from you, subject to legal exceptions.
• Right to correct inaccurate personal information.
• Right to opt out of "sale" or "sharing" of personal information. Because we do not sell or share personal information, there is nothing to opt out of by default. If we ever change that, we will offer a clear opt-out mechanism here and require your affirmative opt-in for any new processing of sensitive personal information.
• Right to limit use of sensitive personal information. "Sensitive personal information" under the CCPA includes account credentials and information about health. We use sensitive personal information only for purposes permitted by Civil Code §1798.121 — namely, providing the Service you have requested, ensuring its security and integrity, and the limited operational purposes the law allows. We do not use it to infer characteristics about you. You can also turn off optional product analytics in Profile > Settings > Privacy at any time.
• Right to non-discrimination. We will not deny service, charge a different price, provide a different level or quality of service, or retaliate against you for exercising any of these rights.

3. Accurate Disclosure of Data Sharing

We do not sell or share your personal information with advertisers or data brokers. We do share limited, de-identified app telemetry with Google LLC (Firebase) for analytics and crash reporting purposes — this sharing requires your consent for Product Analytics and is subject to a Data Processing Agreement for Crash Reporting. See our Privacy Policy §3 for full details.

You may opt out of Product Analytics at any time via Profile > Settings > Privacy > Analytics & Crash Reporting. Turning off analytics stops future sharing. To request deletion of previously transmitted data, use Delete My Analytics Data in the same Settings sheet.

4. How to Exercise Your Rights

You can exercise these rights through any of the channels below:

• In the app: Profile > Export Data (access / portability), Profile > Settings > Delete Account (deletion of all data), Profile > Settings > Privacy > Withdraw Health Data Consent (deletion of consumer health data only), Profile > Settings > Privacy > Analytics & Crash Reporting (limit use of sensitive personal information for analytics).
• By email: privacy@refactorfitness.app. Use the subject line "California Privacy Request" and tell us which right you are exercising. We may need to verify your identity by confirming you control the account email.
• By mail: see Terms of Use §22 (Contact Us).
• Authorized agents: you may use an authorized agent to submit a request. We require written proof of the agent's authority and may still require you to confirm your identity directly.

We will acknowledge receipt within 10 business days and respond substantively within 45 days. If we need more time we will tell you, and the response window may be extended for an additional 45 days as permitted by the CCPA.

5. Global Privacy Control

The Refactor Fitness mobile app does not use browser cookies or tracking technologies, so there is no website signal to honor. The Refactor Fitness marketing website does not use cookies, tracking pixels, or third-party analytics, and therefore there is nothing for the Global Privacy Control browser signal to opt you out of. If we ever introduce optional web tracking, we will treat a recognized GPC signal as an opt-out of "sale" and "sharing".

6. More Information

For full details about how we collect, use, retain, and protect your information, see our Privacy Policy, our Consumer Health Data Privacy Policy, and our AI Data Sharing Consent.

7. Contact

BOGERT CSN 443, LLC d/b/a Refactor Fitness
Email: privacy@refactorfitness.app
Mailing address: see Terms of Use §22 (Contact Us).