
VITAGRIT40
Last updated: 17 August 2026
Privacy Policy
Your trust matters. This policy explains what we collect, why we use it, how we protect it, and the control you have over it. We keep it in plain language, but it is written to meet our obligations under the EU General Data Protection Regulation (GDPR).
Who we are
Vitagrit40 (the “app”) is operated by UAB Ernex, a company registered in Lithuania (the “we”, “us”, “our”). UAB Ernex is the data controller responsible for your personal data. Company: UAB Ernex, Lithuania (registration code: 306098837, registered address: Krokuvos g. 7A-5, LT-09314 Vilnius, Lithuania). Privacy contact: privacy@vitagrit40.com
Information we collect
Account information. Your name and email address. If you sign in with Apple or Google, we receive the account identifier and email associated with that service.
Health and fitness information you provide. To deliver a safe, personalized program, we collect the fitness and health data you choose to enter, including: health-readiness screening responses (our PAR-Q+ questionnaire — for example, questions about heart conditions, chest pain, dizziness, bone or joint issues, and medication), which you complete before starting a program; age, body weight and body measurements; back/spine sensitivity level and daily sitting time; fitness goals, unit preferences (metric/imperial), and workout and progress history. Some of this is special-category (health) data under GDPR, and we treat it accordingly (see Legal bases below).
Subscription and payment information. Subscriptions are processed by the Apple App Store, Google Play, RevenueCat and Stripe. We receive subscription status but we do not collect or store your card details.
Technical and usage information. Basic device and app-usage information (for example, app events and diagnostics) processed through Google Firebase, used to keep the app secure and reliable and to improve it.
An email address you choose to leave when we cannot offer you a program. If your PAR-Q+ answers indicate that you should speak to a physician before starting a new exercise program, we do not create a training plan for you. On that screen you may — entirely optionally — leave an email address so that we can keep your screening answers and let you know that you can come back once you have spoken to your doctor. We store this address together with the fact that you were referred to a physician. We never ask for, and you should not send us, any detail about your medical condition. Leaving this address is optional; the screening result is the same whether you leave it or not.
How we use your data
We use your information to: create and personalize your workout and mobility programs. Personalization is produced by our own template- and rule-based program engine running on Google Firebase. At this stage the app does not send your data to any third-party AI or large language model provider; track your progress and adapt your plan; process and manage your subscription; keep the app secure, prevent abuse, and fix problems; improve our content and features; comply with our legal and accounting obligations.
To let you return after speaking to your doctor. If you left us an email address on the “Consult Your Doctor” screen, we use it to hold your screening answers against your address and to send you a small number of messages inviting you back and explaining how to retake the screening. We do not use this address for general marketing, we do not sell or share it, and you can ask us to delete it at any time.
Legal bases for processing (GDPR)
Performance of a contract — to provide the app and the service you signed up for (Art. 6(1)(b)). Your explicit consent — for processing your health-related (special-category) data, such as your PAR-Q+ responses and body measurements, which we collect only after you give explicit consent in the app (Art. 6(1)(a) and Art. 9(2)(a)). You can withdraw this consent at any time by deleting the relevant data or your account; withdrawal does not affect processing carried out before withdrawal. Legitimate interests — to secure, maintain and improve the app, where this does not override your rights (Art. 6(1)(f)). Legal obligation — to meet accounting, tax and other legal requirements (Art. 6(1)(c)).
Your consent (Art. 6(1)(a) GDPR) — for the optional email address you leave on the “Consult Your Doctor” screen. You give this consent by ticking the box on that screen; it is never assumed. You can withdraw it at any time by writing to privacy@vitagrit40.com, and we will delete the address. Withdrawal does not affect processing carried out before you withdrew.
Data storage, security and location
Your data is stored using Google Firebase infrastructure in the European Union (europe-west1) region, with industry-standard encryption in transit and at rest. We restrict access to your data to what is necessary to operate the service.
Third-party service providers
We share data only with providers that help us run the service, each acting under a data-processing agreement: Google Firebase / Google Cloud — authentication, database, storage, analytics; RevenueCat — subscription management; Stripe — web payment processing; Apple App Store / Google Play — app distribution and in-app purchases. We do not sell your personal data, and we do not share it for third-party advertising.
International data transfers
Our infrastructure is hosted in the EU. However, some of our providers (for example, Google, RevenueCat, Stripe) are based in or may process limited data outside the European Economic Area, including in the United States. Where this happens, the transfer is protected by appropriate safeguards such as the European Commission’s Standard Contractual Clauses or an adequacy decision.
Data retention
We keep your personal data for as long as your account is active. When you delete your account, we delete your personal data, except where we must keep limited records to meet legal, tax or accounting obligations (retention period: up to 10 years for accounting records, as required under Lithuanian law), after which it is deleted.
Email addresses left on the “Consult Your Doctor” screen are kept for up to 12 months and then deleted automatically, unless you have created a Vitagrit40 account in the meantime — in which case the address becomes part of your account and follows the retention rules for accounts. You can ask us to delete it sooner at any time.
Your rights
Under GDPR you have the right to: access the personal data we hold about you; rectify inaccurate data; erase your data (“right to be forgotten”); restrict or object to certain processing; data portability — receive your data in a portable format; withdraw consent at any time. You can access, export and correct much of your data, and delete your account and all associated data, directly from the app’s account settings. For any other request, email privacy@vitagrit40.com. We respond within the timeframes required by law. You also have the right to lodge a complaint with a supervisory authority. Our lead authority is the State Data Protection Inspectorate of Lithuania (Valstybinė duomenų apsaugos inspekcija — VDAI), or the authority in your country of residence.
If you left an email address on the “Consult Your Doctor” screen but never created an account, you can still exercise all of the rights above in respect of that address. Write to privacy@vitagrit40.com from the address in question and we will act on your request.
Account and data deletion
You can permanently delete your account and all associated data at any time from within the app (Account Settings → Delete Account). This action is irreversible.
Children’s privacy
Vitagrit40 is intended for adults and is not directed to anyone under 18. We do not knowingly collect data from minors. If you believe a minor has provided us data, contact privacy@vitagrit40.com and we will delete it.
Changes to this policy
We may update this policy from time to time. If we make material changes, we will notify you in the app or by email, and update the “Last updated” date above.
Contact us
For any privacy question or to exercise your rights, contact: UAB Ernex — privacy@vitagrit40.com