FITWINGS GLOBAL PRIVACY POLICY & TERMS OF USE

1. Introduction & Scope

This Privacy Policy outlines how FitWings collects, uses, protects, and processes your personal data. It is drafted to comply with the General Data Protection Regulation (GDPR) (EU), the UAE Personal Data Protection Law (PDPL), and the Saudi Arabia (KSA) Personal Data Protection Law (PDPL).

2. What Data Do We Collect?

We collect data in three distinct categories to power our "Adaptation Engine", and our systems.

3. Legal Basis for Processing

We process your data under the following legal bases:

1. Contractual Necessity: To deliver the specific "Founder"s Edge" PDF and AI services you requested.
2. Explicit Consent (GDPR Art. 9(2)(a) / UAE PDPL Art. 6): We process your Health & Biometric Data solely based on your explicit, affirmative consent obtained at the time of sign-up (via the "Hard Gate" checkbox) by checking the box and agreeing to our agreement and policies. You may withdraw this consent at any time; however, doing so may render us unable to provide you with personalized plans.
3. Legitimate Interests: To analyze user behavior, improve our algorithms, and detect fraud.

4. Automated Decision Making & AI Profiling

Disclosure: FitWings uses Automated Decision-Making (ADM) and Profiling to generate your fitness and nutrition plans.

• The Logic: We may use our AI "Adaptation Engine," which analyzes your inputs for example but not limited to missed workouts, reported stress, schedule constraints and more, against physiological algorithms to automatically adjust your future nutritional targets and training volume.
• The Consequence: Your daily plan may be altered automatically without human intervention.
• Your Rights: Under GDPR Article 22, you have the right not to be subject to a decision based solely on automated processing if it produces legal effects concerning you. While our wellness plans generally do not produce "legal effects," you retain the right to request human review of any anomaly in your plan.

5. How We Store & Transfer Data (International Transfers)

FitWings operates globally. Your data is stored on secure, encrypted servers (AES-256 standard).

For Users in the UAE and Saudi Arabia (KSA):

We acknowledge strict data localization requirements. Where required by law, we utilize local data centers or rely on specific transfer mechanisms approved by the Saudi Data & AI Authority (SDAIA) and the UAE Data Office, including:

• Standard Contractual Clauses (SCCs).
• Explicit user consent for the international transfer of health data required to render the service.

6. Marketing Communications & Opt-Out

Marketing Emails: We use your Identity Data to send you newsletters, the "Founder"s Edge" tips and advice, our nutrition & training plans, and our product upgrades.

• How to Opt-Out: You may unsubscribe from marketing communications at any time by clicking the "Unsubscribe" link found in the footer of every email.
• Clarification: Unsubscribing from marketing emails does NOT delete your account or your health data. It simply removes you from our marketing distribution list. To delete your data entirely, see "Your Rights" below.

7. Your Data Protection Rights (Global)

Regardless of where you live, FitWings grants you the following rights:

1. Right to Access: Request a copy of the personal data we hold about you.
2. Right to Rectification: Request correction of inaccurate or incomplete data.
3. Right to Erasure ("Right to be Forgotten"): Request the permanent deletion of your account and all associated health data. Note: This action is irreversible.
4. Right to Restriction: Request that we pause processing your data (e.g., but not limited to, if you contest its accuracy).
5. Right to Data Portability: Request transfer of your data to another service provider.
6. Right to Object: Object to our processing of your data for direct marketing purposes.

8. Acceptance of Terms

By accessing the FitWings website, utilizing the "Founder"s Edge Plan Form," or downloading and viewing any of our materials, you agree to be bound by these Terms of Use. If you do not agree, you must immediately discontinue use of our services.

9. The "Founder"s Seat" & Payments

• Deposit: The $25 USD deposit to secure a "Founder"s Seat" creates a priority reservation for our app launch.
• Refund Policy: This deposit is fully refundable ("No-Fail Guarantee") prior to the public launch of the application. Once the application launches and your account is activated, the deposit is credited toward your first month"s subscription.
• Pricing: The "Founder"s Status" locks in a 50% discount on the standard monthly rate for the first 2 months of the first continuous subscription.

10. Intellectual Property

All content generated by FitWings, including but not limited to the "AI Engine," the "Founder"s Edge" PDF, nutrition plans, workout and training plans, text, graphics, logos, and software code, is the exclusive intellectual property of FitWings. You are granted a limited, non-exclusive, non-transferable license to use these materials for your personal, non-commercial use only.

11. AI Output & No Medical Advice Disclaimer

12. Limitation of Liability

To the maximum extent permitted by applicable law, FitWings and its associates shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including without limitation, loss of profits, data, use, goodwill, or other intangible losses, resulting from:

• Your access to or use of or inability to access or use the Service;
• Any conduct or content of any third party on the Service;
• Any injury or health deterioration resulting from following our wellness suggestions.

13. Governing Law & Dispute Resolution