Privacy policy

1. Who we are

Pal is made by PTPal Ltd ("Pal", "we", "us"), a company registered in England and Wales, company number 15817072. Our registered office is 21 Dorchester Place, Kenton Bank Foot, Newcastle upon Tyne, NE13 8BE.

We are the controller of the personal data described in this policy. That means we decide how and why it's used.

This policy covers:

• the Pal app for iPhone and Android;
• Pal on WhatsApp;
• our website, pal.health;
• any emails or messages we send you.

If you use Pal through your employer, gym or another organisation, see section 6.7.

Contact us about privacy: hello@pal.health, or write to us at the address above. Our privacy lead is Chris Davison, Founder.

2. The short version

• Pal is a coach for food, training and wellbeing. To coach you, it needs to know about your body, your goals and your health. That's sensitive, so we only use it with your explicit consent, and you can withdraw that consent at any time.
• We never sell your data and Pal never shows you ads.
• Your coaching conversations are handled by named AI providers acting on our instructions (listed in section 7). They're not allowed to use your data for their own purposes, and we don't use your data to train AI models.
• You choose what your Pals see. "Wins only" is the default. "Open book" shares more. Your chats with Pal and your photos are never shared with Pals.
• Pal reads from Apple Health or Health Connect if you allow it. It never writes to them.
• You can delete your account in the app at any time (You > Settings > Delete account), or from pal.health/delete-account.
• You can complain to us, and to the ICO.

3. What this policy replaces

This version replaces the policy dated 9 October 2025. It's been rewritten for Pal 3.0. The main changes:

• Pals (sharing with people you choose);
• voice notes and calls;
• the named providers who help run Pal;
• Beast Mode;
• clearer retention and deletion information;
• the legal bases we rely on, including explicit consent for health data.

We've also removed wording about using your data to train AI models and about using shared content for promotion. We don't do either.

4. What we collect

4.1 Things you tell us or create

4.2 Things we collect automatically

4.3 Apple Health and Health Connect

If you connect them, Pal reads:

• steps;
• workouts;
• active and total calories burned;
• sleep;
• weight;
• height;
• distance (Android only);
• date of birth and sex (iPhone only, during setup).

Pal uses this to set your daily targets (for example, more food on active days) and to tailor coaching.

• Pal never writes to Apple Health or Health Connect.
• We don't use data from Apple Health or Health Connect for advertising or marketing. We don't sell it, and we don't share it with anyone except the service providers in section 7 who help run your coaching.
• We don't store it in iCloud.
• You can disconnect at any time in You > Settings > Health data connections, or in your phone's settings. If you disconnect in Pal, we delete the health data we synced through that connection.

Pal's use of information received from Health Connect follows the Health Connect Permissions policy, including its Limited Use requirements.

4.4 Information about other people

If you invite someone to be your Pal, you can type a name for them (for example "Rosa"). Only you see it. It's kept until your account is deleted.

Please only tell Pal about other people when it's needed for your coaching.

5. How we use it, and our legal bases

UK data protection law requires a legal basis for each use. For health data we also need a condition under Article 9, and we rely on your explicit consent. You give it on the "Before we start" screen when you set up Pal.

Withdrawing consent.

• You can withdraw your consent to us using your health data at any time, by deleting your account or by contacting us. Pal can't coach you without it, so withdrawing means closing your account.
• You can withdraw other consents (marketing, tracking) separately, at any time, without affecting your coaching.

Automated decisions and profiling. Pal personalises your coaching automatically: your targets, your weekly plan, tips and which features are offered. For example, Beast Mode isn't offered if you've told us you're on GLP-1 medication. These decisions don't have legal or similarly significant effects. You can always change your answers, ask Pal to adjust, or contact us to have a person review anything Pal has done.

Beast Mode. If you switch on Beast Mode, we record when it started and when it ends. Messages sent while it's on are marked so they're kept out of Pal's long-term memory.

6. Pals: sharing with people you choose

6.1 How it works

Pals connects you one-to-one with people you choose: a partner, a friend, a family member, or a professional such as a personal trainer.

• You can have up to ten Pals.
• Your Pals can't see each other unless they connect with each other too.
• You choose, for each Pal, what they see. They choose what you see of them.

6.2 What each sharing level shows

Some extra protections:

• Professionals (PT, coach, physio, dietitian) only see Open book after you confirm it separately.
• Sensitive goals. If your goal involves a GLP-1 medicine, perimenopause or menopause, every Pal starts at Wins only, and your recap is worded gently, with no numbers in notifications.
• Eating disorders. If you've told us about an eating disorder, Pal never creates weight wins or weight suggestions for you, whatever you share.
• You can change a Pal's sharing level at any time, and going back to Wins only takes one tap.

6.3 Invites

When you invite someone:

• we create a link and an 8-character code, valid for 14 days;
• anyone with the link or code can see your first name and the role you chose;
• you send the link yourself, using your phone's share sheet. Pal doesn't access your contacts.

The link uses our attribution provider (AppsFlyer, section 10), so the app can open the right invite after the person installs it.

6.4 Rewards

When someone joins Pal from your invite:

• they get 7 days of full access (once per person);
• you get 7 days for each new Pal who joins through you, up to ten, unless you're already a paying subscriber.

We record each reward and apply it through RevenueCat, our subscription provider. Rewards have no cash value. See the Terms for the full rules.

6.5 Cheers, nudges, messages and recaps

• Cheers and messages are short (up to 140 characters).
• Nudges can be sent after a Pal has been quiet for three days, at most one a day. A nudge reaches your Pal in the app, and by push notification or WhatsApp if they've allowed it. A WhatsApp nudge includes your first name and your message, and is sent through Meta.
• Your weekly recap is ready on Friday evening. Only the Pals you choose see it.
• Mute hides a Pal's messages and notifications, without telling them.
• Remove ends the connection for both of you.
• Report hides a message for you straight away and sends it to us to review. We look at the reported message and the account involved, and we may restrict or close accounts that break our Terms.

6.6 Once you've shared it

Your Pals are people you chose, not our service providers. Once a Pal has seen something, we can't control what they do with it (for example, a screenshot).

A professional you connect with (for example your PT) may hold your information as their own client record, under their own privacy obligations.

6.7 Pal through an organisation

If your employer, gym or another organisation gives you Pal:

• they only get aggregated, anonymised reports (for example how many people are active);
• they never get your individual data, chats or health information;
• Pal may point you to services they offer (for example an employee assistance programme).

7. Who we share data with

We use the service providers below to run Pal. They act as our processors: they may only use your data to provide their service to us, under contracts that require them to protect it. We don't sell personal data, and we don't share it for advertising.

Others we may share with:

• Your Pals, as described in section 6.
• Professional advisers (lawyers, accountants, insurers), under confidentiality.
• Authorities, if the law requires it, or to protect someone's life.
• A buyer or investor, if Pal or its business is sold, merged or restructured. They'd be bound by this policy, and we'd tell you before your data became subject to a different policy.

8. Voice notes, calls and WhatsApp

Voice notes in the app.

• When you send Pal a voice note, we store the recording and send it to our provider to transcribe.
• Pal may reply with a voice note too. If you'd rather not get voice replies, type your message instead.
• Your voice notes and Pal's voice replies are kept with your chat until you clear the chat or delete your account.

Dictation. When you tap to dictate, your phone's speech recognition (Apple or Google) turns your speech into text before it's sent.

Voice calls.

• When you call Pal, your voice streams live to VAPI. Deepgram transcribes it, and ElevenLabs speaks Pal's replies.
• We keep the transcript and a summary of the call so Pal remembers it. We don't keep a recording.
• VAPI keeps a log of each call, including the transcript, until your account is deleted.

WhatsApp.

• If you link WhatsApp, you send us a code from your WhatsApp account, and that's how we learn your number.
• Messages, photos and voice notes you send Pal on WhatsApp go through Meta. We keep the text, and a transcript of voice notes; we don't keep the audio.
• Pal may send you check-ins (usually Monday, Wednesday and Friday) and Pals nudges.
• Reply "pause check-ins" or "stop check-ins" to pause them for 14 days, and "resume check-ins" to start again.
• You can unlink WhatsApp in You > Connections.

9. AI and your data

• Pal's coaching is generated by AI, using the providers in section 7.
• We don't use your personal data to train AI models. We use our AI providers' business services, whose terms say they don't use our customers' data to train their models.
• Some providers may keep data for a short time to detect abuse (for example OpenAI, for up to 30 days).
• AI can be wrong. Please check anything important, and see the Terms (Pal gives general wellbeing guidance, not medical advice).
• We may look at a small number of conversations to fix problems or keep people safe. For example, if you give a reply a thumbs down, or a message is flagged for safety. Only authorised members of our team can do this.

10. Attribution, tracking and ads

• Pal doesn't show ads, and we don't sell your data.
• We use AppsFlyer to understand which links and campaigns bring people to Pal, and to make Pals invite links open the right screen after someone installs the app.
• On iPhone, Pal asks for permission to track using Apple's prompt. If you allow it, AppsFlyer can use your device's advertising identifier (IDFA) to match your install to a campaign. If you don't, we don't access the IDFA, and attribution falls back to aggregated methods. You can change this at any time in Settings > Privacy & Security > Tracking.
• On Android, AppsFlyer may use your advertising ID, but only after you've agreed on the "Before we start" screen. You can reset or delete it in your phone's settings.
• Where we run campaigns on ad platforms (for example Meta, Google or TikTok), AppsFlyer may tell that platform, in limited form, that an install came from its ad. It never shares your health data, logs or chats.
• On our website, see section 16.

11. How long we keep data, and deleting your account

Deleting your account.

• In the app: You > Settings > Delete account.
• Without the app: go to pal.health/delete-account, or email hello@pal.health from the address on your account. We'll confirm it's you before we act on it.
• A 30-day grace period. When you delete your account, it's deactivated straight away, and we keep your data for 30 days in case you change your mind. Sign back in with the same Apple or Google account within those 30 days and you carry on where you left off. If you ask by email and don't want to wait, tell us, and we'll skip the grace period.
• After 30 days, we permanently delete your profile, logs, plans, chats, voice notes, photos, Pals connections and messages, WhatsApp link and Pal's memory of you, and your sign-in. This can't be undone.
• At the same time, we ask our providers to delete what they hold about you (for example calls and chats at VAPI, analytics at Segment, subscription records at RevenueCat), except where they must keep it by law. Some providers keep limited data for a short time under their own terms (for example, see section 9 on abuse monitoring).
• Backups are overwritten within 35 days after that, and the other periods in the table above still apply.
• Deleting your account doesn't cancel your subscription. Cancel it in your App Store or Google Play settings.

12. International transfers

Our main servers are in the EU (Belgium). The UK recognises the EU as giving adequate protection.

Some providers are in the US or other countries (see section 7). When your data goes outside the UK, we make sure it's protected by:

• the UK Extension to the EU-US Data Privacy Framework (where the provider is certified); or
• the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses; or
• a UK adequacy decision (for example for Israel and the EU).

Contact us for a copy of the relevant safeguards.

13. Your rights

Under UK data protection law you can ask us to:

• give you a copy of your data (access);
• correct it (rectification);
• delete it (erasure);
• restrict how we use it (restriction);
• give it to you, or another service, in a portable format (portability);
• object to uses based on legitimate interests, and to direct marketing at any time;
• withdraw consent at any time (this doesn't affect anything done before).

You also have rights about automated decision-making (section 5).

To use any of these, email hello@pal.health. We'll reply within one month, and may need to confirm who you are. It's free unless a request is clearly unfounded or excessive.

14. Complaints

Please tell us first at hello@pal.health. We'll acknowledge your complaint within 30 days and let you know what we're doing about it.

You also have the right to complain to the Information Commissioner's Office:

• ico.org.uk/make-a-complaint
• 0303 123 1113
• Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

15. Age limit

Pal is for people aged 18 and over. We don't knowingly collect data from anyone under 18. If we find out that someone under 18 has an account, we'll delete it. If you think someone under 18 is using Pal, contact hello@pal.health.

16. Our website and cookies

pal.health doesn't use cookies, and it has no advertising or tracking tags, so there's no cookie banner.

• Hosting. Vercel hosts the site. Like any web server, it logs technical data such as your IP address and browser to keep the site running and secure.
• Fonts and store badges. Our heading font loads from Fontshare's servers, and the App Store and Google Play badges load from Apple's and Google's servers. Those servers see your IP address when your browser asks for them. They don't set cookies through our site.
• Visit counts. If we turn on visit counting, we'll use Vercel Web Analytics, which doesn't use cookies, and we'll update this section first.
• Store links. The download buttons go through our attribution provider, AppsFlyer (section 10), before the App Store or Google Play.

Contact form. If you use the "Talk to us" form, we use your details only to reply to you. The form sends your message to our inbox through Resend (in the US, see section 7), and we keep it for as long as the conversation needs (see section 11). The form doesn't set cookies. To block spam it uses a hidden field, checks how quickly the form was filled in, and briefly counts requests from each IP address in memory.

When you email us from the site (for example to delete your account), we use what you send only to deal with your request.

17. Security

We protect your data with:

• encryption in transit (TLS);
• encryption at rest (Google Cloud);
• strict access controls;
• signed, time-limited links for stored audio and photos;
• sign-in through Apple or Google, so we never store a password.

No system is perfectly secure. If a breach puts you at risk, we'll tell you and the ICO as the law requires.

18. Changes to this policy

We'll update this policy when Pal changes. If a change matters (for example a new type of provider, or a new use of your health data), we'll tell you in the app or by email before it takes effect, and ask for your consent again where the law requires it. The date at the top shows the latest version.

Earlier versions are available on request.

19. Contact

• Privacy questions or requests: hello@pal.health
• Everything else: hello@pal.health, or WhatsApp support from the app
• Post: PTPal Ltd, 21 Dorchester Place, Kenton Bank Foot, Newcastle upon Tyne, NE13 8BE