Privacy Policy
Effective: 26 March 2026 · Last updated: 20 October 2026
P247 ("we", "us", "our") operates the P247 mobile application and the website at p247.io (together, the "Service"). This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and your rights regarding that data.
P247 is operated by Commit-IT (ABN 60 137 471 615), based in New South Wales, Australia. We serve users internationally and comply with applicable data protection laws including the Australian Privacy Act 1988, the EU General Data Protection Regulation (GDPR), the UK GDPR, and the California Consumer Privacy Act (CCPA).
1. Data We Collect
1.1 Account Data
When you create an account, we collect:
- Email address
- Name (optional)
- Password (stored as a salted hash, never in plain text)
- Timezone and locale preferences
1.2 Health and Fitness Data
With your explicit consent, we collect health and fitness data from:
- Apple HealthKit: heart rate, heart rate variability, resting heart rate, VO2 max, sleep stages, respiratory rate, blood oxygen saturation, wrist temperature, mindful minutes, steps, active energy, time in daylight, walking speed, workouts, workout routes (GPS of outdoor workouts), running form, body measurements, body composition (weight, body fat percentage, lean body mass), blood pressure, nutrition, date of birth and biological sex
- Connected platforms (Strava, intervals.icu): activity data, training load, fitness metrics and related workout data available through those APIs
- Wearable data via Apple Health: when devices such as Garmin, Whoop or Oura sync into Apple Health / HealthKit, those readings may be available to P247 through HealthKit with your permission
- Manual entries: body composition scans (InBody, DEXA), daily check-ins (subjective feel, soreness, sleep quality, nutrition), notes, goals and target events, injuries you log, heart-rate settings, and your wake-up schedule for the sleep plan
- Blood test results (only if you choose to add them): the photo or PDF you upload, and the markers, values, units and reference ranges read from it or entered by you
- Coach chat: the messages you send, photos you attach to them, the coach's replies, and facts the coach remembers about you from your conversations
- Photos you attach to workouts: including any photo of a workout programme you ask P247 to read
Important: Health data is sensitive personal data. We only collect it after you grant explicit permission through the HealthKit consent screen or by connecting a third-party account via OAuth. You can revoke access at any time through your device settings or the P247 app.
1.3 Security Data
We automatically collect:
- IP address (security; country-level only)
1.4 Website Analytics
Our website uses Google Analytics 4 (GA4) to understand traffic and usage patterns. GA4 collects anonymised usage data including page views, session duration, and referral sources. See our Cookie Policy for details.
2. How We Use Your Data
| Purpose | Data Used | Legal Basis (GDPR) |
|---|---|---|
| Provide the Service (daily briefs, trend analysis, coaching) | Health data, account data, manual entries | Contract (Art. 6(1)(b)) for account data; explicit consent (Art. 9(2)(a)) for health data |
| Provide the daily brief and weekly performance report (rule-based) | Health data, training history, check-ins, events | Explicit consent (Art. 9(2)(a)) |
| AI features: the coach, goal plans and plan adjustments, workout summaries and reading workout programme photos, processed by Anthropic (see section 4) | Health data, nutrition, body measurements, workouts and programmes, events, injuries, coaching preferences, sleep plan, chat messages and photos you attach | Explicit consent (Art. 9(2)(a)), given on the AI features screen, or in Settings |
| Read and summarise your blood test results, processed by Anthropic (see section 4) | Blood test photos or PDFs, or values you enter; markers and reference ranges | Explicit consent (Art. 9(2)(a)) |
| Improve the website | Anonymised website usage data (see section 1.4) | Legitimate interest |
| Respond to support requests | Account data, communications | Contract (Art. 6(1)(b)) |
| Prevent fraud and ensure security | IP address, access logs | Legitimate interest |
3. How Your Data Is Analysed
3.1 Rule-based analysis (our infrastructure)
The daily brief (recovery score and the call for the day) and the weekly performance report (main decision, priorities, confidence level, data gaps and actions) are calculated by fixed rules applied to your own data on our infrastructure. They are not written by an AI model, and they don't send your data to an AI provider.
3.2 Blood test results
Blood test results are sensitive health data. We collect them only if you choose to add them. They are used to show you your markers, how they change between tests, and a plain-English summary for training context. Reading and summarising them uses Anthropic, as described in section 4. They are not used for advertising and are not shared with anyone else. Blood test summaries are not a diagnosis or medical advice; talk to a qualified health professional about any result that concerns you.
4. AI Features and Anthropic
Some P247 features use Anthropic, PBC ("Anthropic"), an AI company based in the United States, through its Claude API. Anthropic acts as our service provider (a data processor): it processes the data we send only to produce a response for P247, under Anthropic's Commercial Terms of Service and Data Processing Addendum. The daily brief and weekly report don't use AI (see section 3).
4.1 Which features use Anthropic, and what each one sends
Each feature sends only the data it needs:
- Coach: up to 15 days of Health metrics (sleep stages, HRV, resting and daily heart rate, blood oxygen, breathing rate, steps, active calories, exercise minutes, distance, time in daylight and VO2 max), nutrition, body composition (including your latest body composition scan), recent workouts and workout programmes, Strava activity names and details, your last 20 chat messages, photos attached to the message you are sending, up to 30 saved memories, injuries, events, coaching preferences and your sleep plan.
- Workout summaries: the workout's name and type, duration, distance, average and maximum heart rate, calories, effort and pace. Workout names can include personal details if you add them. Workout summaries don't add your photos, messages, blood tests, body measurements or daily HRV and sleep.
- Blood test reading: the blood test report you upload (photo or PDF), or the values you enter, so the markers can be read and summarised. This includes values you enter manually.
- Workout programme photos: the photo of a workout programme you ask P247 to read. Other workout photos are not sent.
- Goal plans and plan adjustments: when you ask P247 to create a goal plan or adjust one, your goal and event details, training days, experience and equipment, a summary of recent health signals, recent workouts and injuries you've logged. Plan changes only apply when you approve them.
Your profile name and email address are not sent to Anthropic, and if your full name or email appears in text we send, it is replaced first. Messages you type, and photos and files you upload such as blood test reports, are otherwise sent as you provide them and may contain identifying details.
4.2 Your consent, and how to withdraw it
A one-time "AI features" screen in the app explains what is sent, with the choice to Agree or choose Not now. The same screen is also available in Settings > Health data and privacy. In the app, the coach, blood test reading and programme photo reading send data only after you agree on that device. Goal plans and workout summaries are also checked by our server against your account setting. If you choose Not now, the coach, goal plans and plan adjustments, new workout summaries, blood test reading and programme photo reading stay off. Your saved plans, workout metrics and the rest of P247 keep working.
Your choice for the coach, blood test reading and programme photo reading is stored on each device. Your goal plans and workout summaries choices are saved to your P247 account and apply on all your devices. Agreeing on the AI features screen turns workout summaries on. Choosing Not now or turning AI features off turns goal plans and workout summaries off for your account. If what these features send changes, the app may ask you again before sending anything new.
You can withdraw consent at any time by turning AI features off in Settings > Health data and privacy. This stops new requests, including new goal plans and plan adjustments; requests already sent may finish. Saved plans and workout summaries already made aren't deleted, and saved plans stay readable.
4.3 How long Anthropic keeps data
Anthropic's published policy for API customers says: "For Anthropic API users, we automatically delete inputs and outputs on our backend within 30 days of receipt or generation". The exceptions under that policy are: where a customer uses an Anthropic service with longer retention, or has agreed a different arrangement with Anthropic; where Anthropic needs to keep data longer to enforce its Usage Policy; and where the law requires it. If Anthropic's automated trust and safety systems flag content as violating its Usage Policy, Anthropic says it may keep the inputs and outputs for up to 2 years, and trust and safety classification scores for up to 7 years. See Anthropic's article "How long do you store my organization's data?" for the current terms, as Anthropic may update them.
4.4 Model training
Anthropic does not use inputs or outputs from its commercial API to train its models by default (see "Is my data used for model training?"). P247 does not use your data to train AI models.
4.5 Deleting your data
Deleting your P247 account deletes P247's copy of your data (see section 7). Backups, including those taken before maintenance, are deleted within 30 days. Deleting your account does not recall data already sent to Anthropic; Anthropic keeps and deletes that data under its own retention terms, described in section 4.3.
4.6 Not sold, not used for advertising
We do not sell your data, to AI companies or anyone else, and we do not use it for advertising.
4.7 Processing outside Australia
Anthropic is based in the United States. When you use these features, the data they send is disclosed to Anthropic as an overseas recipient and may be processed in the United States or in other countries where Anthropic or its subprocessors operate. Anthropic processes it under its Commercial Terms of Service and Data Processing Addendum, which incorporates the EU Standard Contractual Clauses. See also section 11.
5. Data Sharing
We do not sell your personal data. We share data only in these circumstances:
- Service providers: hosting (our own server in Australia), network delivery and security (Cloudflare, Inc., United States), AI processing (Anthropic, PBC, United States: only for the AI features in section 4, and only with your consent), analytics (Google), email delivery. All bound by data processing agreements.
- Connected platforms: when you connect Strava or intervals.icu, we exchange data with those platforms using their APIs under their own privacy policies. Apple Health / HealthKit data is read on your device with your permission. We only read data from these sources; we do not write your P247 data back to them.
- Legal requirements: if required by law, court order, or to protect the safety of our users.
- Business transfer: in the event of a merger, acquisition, or sale of assets, your data may be transferred. We will notify you before this happens.
6. Data Storage and Security
- Data is encrypted in transit: the app and website connect to our servers over HTTPS (TLS)
- Database access is restricted to authenticated application services and a small number of authorised staff for support
- API authentication uses per-user keys; passwords are salted and hashed
- We conduct regular security reviews of our infrastructure
- Hosting (our own server in Australia), network delivery and security (Cloudflare, Inc., United States). Where data is processed outside your jurisdiction (for example, AI processing by Anthropic in the United States, see section 4), we ensure appropriate safeguards are in place (Standard Contractual Clauses for EU data transfers)
7. Data Retention
- Active accounts: your data is retained for as long as your account is active
- Deleted accounts: upon account deletion, all personal data is permanently removed within 30 days.
- Backups: Backups, including those taken before maintenance, are deleted within 30 days.
- Data sent to Anthropic: kept and deleted by Anthropic under its own retention terms (see section 4.3). Deleting your P247 account does not recall it.
8. Your Rights
All Users
- Access: request a copy of all data we hold about you
- Correction: update or correct inaccurate data
- Deletion: delete your account and all associated data
- Withdraw consent: revoke HealthKit or wearable access at any time, and turn off AI features in Settings > Health data and privacy
- Data portability: request a machine-readable export from privacy@p247.io
EU/UK Residents (GDPR)
In addition to the above, you have the right to:
- Restrict processing of your data
- Object to processing based on legitimate interest
- Lodge a complaint with your local Data Protection Authority
- Not be subject to decisions based solely on automated processing (you can request human review of any AI-generated recommendation by emailing privacy@p247.io)
California Residents (CCPA)
You have the right to:
- Know what personal information we collect and why
- Request deletion of your personal information
- Opt out of the sale of personal information (we do not sell your data)
- Not be discriminated against for exercising your privacy rights
Australian Residents
Under the Australian Privacy Act 1988 and the Australian Privacy Principles (APPs), you have the right to access and correct your personal information. You may also complain to the Office of the Australian Information Commissioner (OAIC) if you believe we have breached the APPs.
9. Apple HealthKit Compliance
P247 complies with Apple's HealthKit guidelines:
- We do not use HealthKit data for advertising or marketing
- We do not sell HealthKit data to third parties
- We do not use HealthKit data for data mining or profiling, and do not store it in iCloud
- We do not share HealthKit data with third parties for their own purposes
- HealthKit data is sent over HTTPS to P247's servers
- With your permission, the relevant data is sent to Anthropic, acting as our service provider, for the coach, goal plans and workout summaries (see section 4). It is not sold or used for advertising
- HealthKit data is used solely to provide the core features of the Service (daily briefs, weekly reports, coach chat, goal plans, heart-rate zones and the sleep plan)
- Users must explicitly grant permission for each HealthKit data type we access
10. Children's Privacy
P247 isn't directed at children under 13, and we don't knowingly collect personal information from children under 13. If you're under 18, please use P247 with a parent's or guardian's permission. If you believe a child under 13 has given us personal information, contact us and we'll delete it.
11. International Data Transfers
P247 is based in Australia and serves users globally. Your data may be transferred to and processed in countries other than your own. In particular, if you use the AI features in section 4, the data they send is disclosed to Anthropic, which is based in the United States. Network delivery and security for the Service are provided by Cloudflare, Inc., which is also based in the United States. When we transfer data internationally, we use:
- EU Standard Contractual Clauses (SCCs) for transfers from the EU/EEA
- UK International Data Transfer Agreement/Addendum for transfers from the UK
- Contractual protections with all third-party service providers
12. Changes to This Policy
We may update this policy from time to time. We will notify you of material changes via email or a notice in the app. The "Last updated" date at the top reflects the most recent revision.
13. Contact Us
For privacy inquiries, data access requests, or complaints:
- Email: privacy@p247.io
- Address: PO Box 6853, Norwest NSW 2153, Australia
We aim to respond to all privacy requests within 30 days (or sooner where required by law).