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Privacy
Policy
Your privacy is important to us. In this Privacy Policy, we explain how we collect, use and protect your personal data in the Tsemppi service.
This is a translation of the original Finnish document. In case of any discrepancy, the Finnish version shall prevail.
1. Data controller
The processing of your personal data is the responsibility of:
Tsemppi Fitness Oy
- Business ID: 3377898-6
- Address: Kolmas Linja 30 B, Helsinki
- Email: info@tsemppiapp.fi
2. What data we collect
We collect the following data in order to provide the service:
Basic information
Name, email address, date of birth, gender
Account information
Username, password (encrypted), profile picture
Training data
Training history, workouts, weights, repetitions, progress data
Body data
Height, weight, limitations (optional)
Health and fitness data
Workouts you import from Apple Health or Health Connect: type, duration, distance, energy burned, heart rate and elevation gain (optional)
Location data
The GPS route of outdoor workouts, and your location for gym search (optional, see section 5)
Usage data
How you use the application, device information, IP address
Note: Heart rate is health data. We store it only if you connect Apple Health or Health Connect and import workouts from there, and you can delete imported workouts at any time. Training, body and health data are optional, and you decide what you save.
3. Artificial intelligence and data processing
Tsemppi uses artificial intelligence to create personalised training programmes. Here we explain exactly how the AI works:
What data the AI uses
- •Goal: Muscle growth, strength, fat loss or performance
- •Level: Beginner, intermediate or advanced
- •Training frequency: How many times a week you want to train
- •Workout duration: Target time per workout
- •Equipment: Gym, basic equipment or home training
- •Limitations: Any injuries or limitations (knee, shoulder, back, hip)
Third-party AI service
To generate training programmes, we use OpenAI’s GPT-4o-mini model. When you create a new training programme:
- •We send OpenAI only the onboarding information listed above (goal, level, frequency, duration, equipment, limitations)
- •We do not send personal identifiers such as your name, email address or username
- •OpenAI does not use the data to train its models when the service is used via the API
- •The data is processed in accordance with EU data protection regulations
Data storage
- •All user data is stored on our own servers within the EU
- •Generated training programmes are saved to your account, not with OpenAI
- •Training history and workouts are kept only in our own database
Limitations of AI: The AI creates a training programme based on the information you provide and our existing exercise database. AI does not replace professional advice, and we recommend consulting a doctor before starting a new exercise programme, especially if you have health-related limitations.
4. Strength level and muscle points
Tsemppi calculates metrics describing your progress based on your training data:
Strength level metric
The strength level is based on standardised powerlifting formulas and takes into account:
- •Weights lifted: Maximum lifts in different exercises
- •Body weight: Relative strength in relation to body weight
- •Gender: Comparison with gender-specific averages
Muscle map and progress
The muscle map visualises the load of your workouts:
- •Intensity: Calculated based on sets, repetitions and weight
- •Target muscles: Each exercise targets specific muscle groups as defined in our exercise database
- •PR tracking: Personal records are saved automatically
Note: These metrics are indicative and are intended to motivate you and to track progress. They are not medical assessments.
5. Application permissions
Tsemppi may request the following permissions on your device. Each permission is optional, and you can manage them in your device settings:
Camera
OptionalWe use the camera to take a profile picture and to save workout videos and progress photos to your profile.
Notifications
OptionalWe use notifications to remind you of workouts, to notify you of community activity (likes, comments, followers) and of replies to support messages.
HealthKit (iOS)
OptionalThe HealthKit integration enables training data to be synchronised with Apple’s Health app, so that you can track all your physical activity in one place.
Health Connect (Android)
OptionalThe Health Connect integration brings workouts from your watch and other fitness apps into your training history (type, duration, distance, energy burned, heart rate and elevation gain), and saves the workouts you finish in Tsemppi and your weight to Health Connect. We read only the data types you allow, and we never use them for advertising. We do not read workout routes from Health Connect.
Location
OptionalWhen you start an outdoor workout, Tsemppi records the GPS route, distance and pace, including while the screen is locked, and stops as soon as you finish. The route coordinates stay on your phone: our server stores only the distance, splits and the shape of the route, without coordinates. In gym search, your location is sent to Google’s place search to find gyms near you, and it is not stored.
Note: The application works fully without these permissions. We only request permission when you use the feature in question for the first time.
6. How we use your data
We use your data for the following purposes:
- ✓Creating personalised training programmes with the help of AI
- ✓Tracking your progress and visualising it as a muscle map
- ✓Managing your user account and login
- ✓Providing community features (if you share workouts)
- ✓Developing and improving the service
- ✓Customer communications and support
7. Data security
We protect your data carefully:
Encryption
All data is encrypted both in transit (TLS) and at rest. Passwords are hashed using the bcrypt algorithm.
Secure infrastructure
We use data centres located within the EU (MongoDB Atlas)
Access control
Authentication based on JWT tokens, 90-day session validity
Regular audits
We review our security practices regularly
8. Sharing of data
We do not sell your data
Your personal data is never sold to third parties for marketing purposes.
We share data only as follows:
- •OpenAI (GPT-4o-mini): Generation of training programmes – onboarding information only, no personal data
- •Service providers: Cloud services and infrastructure (MongoDB Atlas, Sentry error monitoring)
- •Community features: With other users, only if you yourself choose to share your workouts
- •Legal obligations: With authorities, only where required by law
9. Cookies and analytics
We use cookies to ensure that the service functions:
Necessary cookies
Login, session management – these cannot be disabled
Analytics cookies
Help us understand how the application is used
Performance cookies
Improve the speed and functioning of the application
You can manage your cookie settings in the application settings or via your browser.
10. Data retention period
- 👤User data: We retain it for as long as your account is active
- 💪Training data: We retain it for as long as your account remains valid, so that you can track your progress
- 🗑️After account deletion: Data is deleted within 30 days
- 📊Anonymised statistics: We may retain anonymised data in order to develop the service
- ⏰Session expiry: After 90 days of inactivity, you must log in again
11. Your rights (GDPR)
You have the following rights in relation to your personal data:
Right of access
You can request a copy of all data collected about you
Right to rectification
You can correct inaccurate or incomplete data
Right to erasure
You can delete your account in the application settings ("right to be forgotten")
Right to restriction of processing
You can restrict the processing of your data 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, send an email to info@tsemppiapp.fi. We will respond to your request within 30 days.
12. Underage users
Tsemppi is intended primarily for adult users. If you are under 16 years of age:
- •You need the consent of your guardian to use the service
- •Your guardian has the right to review and delete the minor’s data
- •We do not knowingly collect data from children under 13 years of age
13. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes:
- 📱By notification in the application
- 📧By email
- 🌐On our website
We recommend that you review this Privacy Policy regularly. By continuing to use the service after the changes, you accept the updated Privacy Policy.
14. Right to lodge a complaint
If you consider that the processing of your personal data infringes data protection legislation, you have the right to lodge a complaint with a supervisory authority:
Office of the Data Protection Ombudsman
- Visiting address: Lintulahdenkuja 4, 00530 Helsinki
- Postal address: P.O. Box 800, 00531 Helsinki
- Email: tietosuoja(at)om.fi
- Switchboard: +358 (0)29 566 6700
15. Contact us
If you have any questions about data protection or wish to exercise your rights: