Operatr Privacy Policy

Effective Date: September 10, 2026

This Privacy Policy explains how Operatr AI, Inc., doing business as Operatr ("Operatr," "we," "us," or "our"), collects, uses, stores, shares, and protects personal information when you use our mobile application, website, software, and related services (collectively, the "Service").

This policy also explains the choices and rights that may be available to you under applicable privacy laws.

1. Who We Are

Operatr provides business management software for personal trainers, fitness professionals, coaches, freelancers, and other service professionals.

For personal information that we collect directly from Operatr users for our own purposes, Operatr AI, Inc. generally acts as the data controller or business, depending on the applicable law. When a user enters personal information about that user's own clients into Operatr, the user may act as the controller or business and Operatr may act as a processor or service provider on the user's behalf, depending on the circumstances and applicable law.

2. Information We Collect

The information we collect depends on how you use Operatr.

Account and Profile Information

When you create or manage an Operatr account, we may collect:

• Name
• Email address
• Username or account identifier
• Password or authentication information
• Profile and professional information
• Country or region
• Account preferences

Passwords may be managed through secure authentication infrastructure and are not intended to be stored in readable form.

Business Information

When you use Operatr to manage your business, you may provide information such as:

• Monthly income targets
• Rates and packages
• Business goals
• Availability and preferred working days
• Scheduled, completed, cancelled, or missed sessions
• Revenue and projected revenue
• Other business performance information

Client Information Entered by Users

Operatr may allow you to enter information about your own clients, including client names, session information, rates, packages, scheduling information, and payment or revenue status associated with sessions.

You are responsible for providing any notices and obtaining any permissions, consents, or other lawful basis required before providing another person's personal information to Operatr.

Operatr is not intended to be used as a medical records system. Unless we specifically introduce functionality designed for that purpose, users should not enter detailed medical information, diagnoses, protected health information, government identification numbers, or other highly sensitive personal information about clients.

Payment and Subscription Information

When you purchase a subscription, payments may be processed through third parties such as Apple, Google, Stripe, or another payment provider. Depending on the payment method, we may receive subscription status, plan information, payment status, billing history, transaction identifiers, and renewal dates. Operatr does not necessarily receive or store your complete credit or debit card number when a third party processes the payment.

Referral and Affiliate Information

If you participate in a referral, affiliate, ambassador, or partnership program, we may collect referral codes and links, referral source, referred-user attribution, conversion information, commission or credit amounts, payout information where required, and fraud-prevention information.

Usage, Device, and Technical Information

When you use Operatr, we and our service providers may automatically collect information such as:

• IP address
• Device type and operating system
• App version and browser type
• Session activity
• Pages or screens viewed
• Features used and interaction events
• Error, crash, and diagnostic information
• Approximate location derived from IP address
• Referral source and attribution information

Communications

If you contact us, participate in research, provide feedback, or communicate with our team, we may retain the information you provide and our communications with you.

3. How We Use Information

We may use personal information to:

• Create, authenticate, and manage accounts
• Provide and personalize the Operatr Service
• Manage subscriptions and payment status
• Calculate business metrics, projections, and progress toward targets
• Manage client and session information at the user's direction
• Provide calendar, scheduling, notification, and reminder functionality
• Provide customer support and respond to communications
• Operate referral, affiliate, ambassador, and partnership programs
• Prevent fraud, abuse, and security incidents
• Diagnose errors and maintain the reliability of the Service
• Analyze product usage and improve existing features
• Develop and test new features
• Communicate product, service, and policy updates
• Comply with legal obligations and enforce our Terms of Service

4. Analytics and Product Monitoring

We may use analytics, diagnostics, and product-monitoring providers, including tools such as PostHog or similar services, to understand how users interact with Operatr. Analytics events may include account creation, onboarding completion, feature usage, session creation, scheduling activity, screen views, time spent within parts of the Service, errors, and performance events.

We use this information to understand product performance, improve the user experience, identify technical issues, prevent abuse, and develop Operatr. Our App Store privacy disclosures and this Privacy Policy should be updated if our analytics providers, SDKs, or data practices materially change.

5. How We Share Information

We may share personal information with service providers that help us operate Operatr, including providers of cloud infrastructure, databases, authentication, payment processing, analytics, diagnostics, email and communications, customer support, security, fraud prevention, and app distribution. We expect service providers to process personal information only for authorized purposes and subject to appropriate contractual and security obligations.

Legal Requirements

We may disclose information where we reasonably believe disclosure is required by law, court order, subpoena, regulatory request, or similar legal process.

Protection of Rights and Safety

We may disclose information where reasonably necessary to investigate fraud, security threats, abuse, violations of our Terms, or threats to the rights or safety of Operatr, our users, or others.

Business Transactions

If Operatr is involved in a merger, acquisition, financing, reorganization, sale of assets, or similar corporate transaction, information may be transferred as part of that transaction, subject to applicable law.

At Your Direction

We may share information when you explicitly direct or authorize us to do so.

6. Sale, Sharing, and Advertising

Operatr does not currently sell personal information for monetary compensation and does not currently use personal information for cross-context behavioral advertising. If these practices materially change, we will update this Privacy Policy and provide any choices or opt-out mechanisms required by applicable law.

7. Cookies and Similar Technologies

Our website and Service may use cookies, local storage, software development kits, pixels, or similar technologies for authentication, security, remembering preferences, analytics, product performance, and referral attribution. Where required by applicable law, we will request consent before using non-essential technologies.

8. Legal Bases for Processing

Where laws such as the GDPR or UK GDPR apply, we may process personal information under one or more of the following legal bases:

• Contract: where processing is necessary to provide the Service or perform our agreement with you.
• Legitimate interests: where processing is reasonably necessary to operate, secure, support, and improve Operatr, prevent fraud, understand product performance, and run our business, balanced against your rights and interests.
• Consent: where applicable law requires consent, including for certain marketing communications, cookies, or tracking technologies. You may withdraw consent where applicable.
• Legal obligations: where processing is necessary to comply with law or legal requirements.

9. International Data Transfers

Operatr is based in the United States and may use service providers located in the United States or other countries. As a result, information may be processed outside the country where you live. Where applicable data protection law requires safeguards for international transfers, we will use appropriate mechanisms, which may include recognized contractual safeguards such as Standard Contractual Clauses or applicable UK transfer mechanisms.

10. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy. Retention depends on factors such as whether your account is active, the type of information, contractual requirements, security and fraud-prevention needs, legal or regulatory obligations, and applicable limitation periods.

When an account is deleted, personal information associated with the account will be deleted or de-identified within a reasonable period, except information we need to retain for legal, security, fraud-prevention, accounting, tax, dispute-resolution, or similar legitimate purposes. Information may remain temporarily in encrypted backups or disaster-recovery systems until those backups are overwritten under our normal retention cycle.

11. Account and Data Deletion

Users may initiate deletion of their Operatr account using the account deletion functionality provided within the app or by contacting areyoufree@operatrapp.com. Account deletion is intended to remove the user's account and associated personal information except information that Operatr is legally required or reasonably permitted to retain.

If you entered personal information relating to your own clients, deleting your account will also initiate deletion of client information associated with that account, subject to applicable legal retention requirements and temporary backup retention.

Deleting an Operatr account may not automatically cancel a subscription managed through Apple, Google, or another third-party provider. Users should separately manage those subscriptions through the applicable provider where necessary.

12. Your Privacy Rights

Depending on where you live, you may have rights regarding your personal information. These may include rights to access, receive a copy of, correct, delete, restrict, or object to certain processing of your information; withdraw consent; receive certain information in a portable format; opt out of certain sales or sharing where applicable; and lodge a complaint with an appropriate data protection authority.

To exercise a privacy right, email areyoufree@operatrapp.com or use privacy controls made available within the Service. We may need to verify your identity before completing certain requests. We will not unlawfully discriminate against you for exercising applicable privacy rights.

13. California Privacy Rights

California residents may have additional rights under applicable California privacy laws, including rights to know, access, correct, or delete certain personal information and, where applicable, to opt out of the sale or sharing of personal information. Operatr does not currently sell personal information for monetary compensation or share it for cross-context behavioral advertising. If these practices change, we will provide any legally required opt-out mechanisms.

California residents may contact areyoufree@operatrapp.com to submit an applicable privacy request.

14. European Economic Area and United Kingdom Rights

If applicable European or UK data protection law applies to you, you may have rights including access, rectification, erasure, restriction, objection, portability, and withdrawal of consent. You may also have the right to complain to the supervisory authority in the country where you live or work. UK residents may have the right to complain to the UK Information Commissioner's Office.

15. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. These may include access controls, encryption, secure authentication, monitoring, infrastructure protections, and limitations on employee or contractor access. No online service or storage system can guarantee absolute security. Users are responsible for maintaining the confidentiality of their account credentials and should contact us if they suspect unauthorized access.

16. Children's Privacy

Operatr is intended for adults and is not directed to children under 18. We do not knowingly permit children under 18 to create Operatr accounts. If we learn that personal information was collected from a child in circumstances where collection was not legally permitted, we will take appropriate steps to delete it.

17. Automated Calculations and Recommendations

Operatr may automatically process information you provide to generate calculations, projections, suggestions, business insights, or similar outputs. For example, Operatr may calculate how much additional revenue you need to achieve a monthly target or estimate the number of additional sessions required based on your existing rates. These features are designed to assist with business planning. Unless expressly stated otherwise, Operatr does not use automated processing to make decisions that produce legal or similarly significant effects about users.

18. Marketing Communications

With your permission or where otherwise permitted by law, we may send communications relating to Operatr features, launches, education, promotions, and other updates. You can unsubscribe from marketing emails using the unsubscribe mechanism in those messages. You may continue to receive essential service communications relating to your account, security, payments, or material Service changes.

19. Third-Party Links and Services

Operatr may contain links to or integrations with third-party services. Their privacy practices are governed by their own policies. We encourage users to review the privacy policies of third-party services they choose to use.

20. Changes to This Privacy Policy

We may update this Privacy Policy as Operatr evolves, our technology changes, or legal requirements change. When we make material changes, we will update the effective date and provide additional notice where required by applicable law.

21. Contact Us

For privacy questions, requests, or complaints, contact:

The Delaware address above is Operatr AI, Inc.'s registered office. Email is the preferred method for privacy requests and ordinary support.