PRIVACY POLICY

Eureka and Eureka Engine | FreeGym AI Products

Effective Date: June 25, 2026
Last Updated: June 26, 2026

1. Introduction

Eureka and Eureka Engine are separate FreeGym products (together, the "Products", and individually, a "Product"). In this Privacy Policy, "we", "us", and "our" mean FreeGym. The Products are personal AI health-coaching and health-information organization tools from the makers of FreeGym, 10X Longevity, and FreeGym-Wiki. They are designed to remember context, organize health and fitness information, reason carefully about noisy data, and help guide the next useful step across training, nutrition, recovery, pain, behavior change, family health responsibilities, and medical preparation.

That means the Products may handle highly sensitive information: lab reports, medications, injuries, symptoms, menstrual and reproductive health context, wearable data, food patterns, mental and emotional state, family-care notes, and private conversations.

This Privacy Policy explains what we collect, why we collect it, how we use it, when it may be shared, how long we keep it, and what choices and rights you have.

This policy applies to:

the Eureka Engine website and any Eureka website, landing page, or waitlist page;
Eureka and Eureka Engine waitlists and early-access onboarding;
conversations, memory, documents, reminders, reports, and related features in either Product;
communications with us about either Product; and
any paid or unpaid access to either Product unless a later written policy or agreement says otherwise.

The Products use the same login and sign-up system as FreeGym. The FreeGym Privacy Policy also applies to your account, profile, community activity, direct messages, public posts, and other FreeGym platform features. This policy covers the additional Product-specific layer for Eureka and Eureka Engine.

2. Who We Are

Eureka and Eureka Engine are operated by FreeGym.

Neither Product is a hospital, clinic, emergency service, or licensed healthcare provider. The Products are AI coaching and health-information organization tools. They do not diagnose, treat, cure, prescribe medication, replace your doctor, or provide emergency care. Product outputs, memories, summaries, reminders, safety checks, and recommendations are AI-generated and may be wrong, incomplete, inconsistent, delayed, or outside the relevant Product's intended scope.

3. Our Privacy Commitments

Because the Products may handle consumer health data, we apply stricter internal rules than we would for an ordinary website.

We do not sell your personal data. We do not sell, rent, or trade your health data, conversations, documents, or profile information.

We do not share your health data for advertising. We do not disclose your identifiable Product health data to advertisers, data brokers, or cross-context behavioral advertising networks.

We do not use your private Product conversations to train public AI models. We do not use or knowingly permit your identifiable conversations, files, health history, or memory to train public foundation models.

We minimize human access. Private Product conversations and files are not casually reviewed by our team. Human access is limited to the situations described in this policy.

We separate public content from private coaching data. Public FreeGym posts are public because you chose to publish them. Private Product conversations, uploaded reports, and personal memory are treated differently.

We do not build the Products around selling you devices, blood panels, or supplements. The Products may reason about labs, wearables, medications, and supplements, but we do not treat those data sources as automatically reliable or as products we need to defend.

4. Information We Collect

We collect different information depending on whether you are only visiting a website, joining a waitlist, or using either Product itself.

4.1 Website and Waitlist Information

When you visit the Eureka Engine website, a Eureka page, or join either waitlist, we may collect:

email address;
name, if requested;
country, city, time zone, or broad location if you provide it or if needed for cohort planning;
waitlist answers, interests, feedback, and messages you send us;
referral source, campaign source, or page that led you to the site;
technical logs such as IP address, browser type, device type, operating system, language, and approximate access time; and
basic site interaction data such as pages loaded, buttons clicked, or form submission status.

When you submit a Eureka or Eureka Engine waitlist form, we collect and process the email address and any related waitlist information you provide for early-access communication, launch updates, cohort planning, and product feedback.

4.2 Account and Identity Information

Because the Products use the same FreeGym login and sign-up system, we may collect:

name, username, email address, password authentication data, or Google or Apple sign-in information;
profile photo or display name if imported from an account provider;
account settings, preferences, consent records, and communication preferences;
device sessions, login events, and security logs; and
support history connected to your account.

4.3 Product Conversations and Memory

To make the Products work as continuous AI coaches, we may collect and store:

prompts, messages, voice/audio recordings and transcripts, images, files, screenshots, PDFs, and other material you submit;
Product responses;
chat history;
summaries, reports, plans, checklists, tables, doctor-visit notes, and other artifacts generated for you;
feedback, edits, ratings, corrections, or flagged mistakes;
long-term memory items, such as goals, constraints, active issues, resolved issues, preferences, family responsibilities, and recurring patterns; and
reminders, tasks, follow-ups, and open loops that the Products are tracking for you.

4.4 Health, Fitness, Lifestyle, and Family-Care Information

If you choose to share it, the Products may process:

health goals, fitness goals, training history, current training, exercise logs, pain, injuries, movement limitations, rehab context, and sport-specific needs;
nutrition patterns, food logs, dietary preferences, intolerances, cravings, supplements, hydration, alcohol, caffeine, and practical food constraints;
sleep, recovery, energy, mood, stress, emotional state, routines, habits, motivation, and behavior-change context;
body metrics, photos, progress notes, wearable exports, heart rate, HRV, sleep-stage data, activity data, recovery scores, glucose readings, blood pressure, or other health measurements;
lab reports, prescriptions, medication lists, supplement labels, doctor notes, discharge summaries, imaging reports, and medical timelines;
menstrual health, contraception, pregnancy, postpartum, perimenopause, menopause, reproductive health, and related symptoms if you choose to provide them;
family-care information, such as a parent's medications, appointments, lab reports, care routines, reminders, or doctor-visit preparation; and
any other health-related details you provide in conversation or upload as files.

You choose what to share. Do not submit information that is not relevant to the Products.

4.5 Information About Other People

The Products are designed to help with family health responsibilities, but that creates privacy obligations. If you submit information about a parent, spouse, child, patient, client, or any other person, you confirm that:

you have their permission or legal authority to share it;
the information is accurate to the best of your knowledge;
you are not violating a professional, legal, employment, or confidentiality duty by uploading it; and
if the person is a minor, you are the parent or legal guardian, or you have appropriate consent from the parent or legal guardian.

We may delete or restrict third-party information if we believe it was submitted without proper authority.

4.6 Public Content

If Product conversations, summaries, or outputs are shared to FreeGym, a public page, a community post, or another public surface at your direction, that shared content may be visible to others. Public content is handled according to the privacy settings and terms of the surface where it is posted.

We do not treat a private Product conversation as public unless you take an action to share it or instruct us to share it.

4.7 Communications With Us

If you email us, message us, respond to a survey, participate in early-access feedback, or contact support, we may keep the communication, your contact details, and any related files so we can respond and improve the Products.

4.8 Payment and Billing Information

The Products do not currently have a payment processor connected to the public product websites. If we introduce paid subscriptions, paid coaching, paid early access, paid reports, or paid add-ons, we may collect billing name, billing address, transaction status, invoice details, plan type, renewal status, and payment support records. Any payment processor and its applicable terms will be disclosed when payments are introduced.

4.9 Information From Third Parties

We may receive information from:

login providers such as Google or Apple, if you sign in through them;
cloud, email, waitlist, analytics, or security providers that support the Products;
AI model providers that process your request so the Products can respond;
public sources such as FreeGym-Wiki, GitHub, or public contributor profiles used to render public website content; and
people you authorize, such as a caregiver, family member, coach, or clinician.

5. How We Use Information

We use information for the following purposes.

5.1 To Provide the Website and Waitlist

We use website and waitlist information to:

operate the website;
process waitlist signups;
send launch, cohort, and early-access communications;
prevent spam or abuse;
understand interest in the Products; and
respond to messages or support requests.

5.2 To Operate the Products

We use your information to operate features intended to:

generate responses;
remember context across sessions;
build and update a working health profile;
organize files, reports, timelines, reminders, tasks, and follow-ups;
personalize guidance to your goals, history, constraints, preferences, and current state;
prepare summaries, doctor-visit notes, checklists, plans, and other artifacts you request;
attempt to identify when data is unreliable, noisy, missing, or outside coaching scope;
attempt to identify when a question appears outside the Products' scope and advise you to seek appropriate professional or emergency care yourself; and
maintain continuity so you do not have to explain your life from zero each time.

These are intended product functions and data-processing purposes, not guaranteed outcomes. Because the Products are AI-based and non-deterministic, similar prompts may produce different outputs, safety checks may not trigger, memory may be incomplete, and guidance may be wrong or outside scope.

5.3 To Support Health-Safety Boundaries

We may use information to support automated safety checks, including to:

attempt to identify when a question appears to involve emergency symptoms, medication changes, pregnancy concerns, severe pain, mental health crisis, or other high-risk situations;
recommend that you contact a doctor, emergency service, or qualified professional yourself;
ask clarifying questions before giving guidance;
decline to answer requests that appear unsafe or outside scope; and
improve internal safety checks and product evaluation.

These safety checks are automated and imperfect. The Products may fail to identify a high-risk situation, may misunderstand your context, or may still produce an answer outside their intended scope, especially if a user repeatedly prompts, rephrases, or pressures the system. Any such output remains AI-generated information only and should not be treated as medical advice, medical clearance, diagnosis, treatment, or an instruction to ignore professional care.

5.4 To Improve the Products

We may use de-identified, aggregated, or privacy-protected information to:

find product failures;
improve safety checks;
evaluate whether the Products overextend weak evidence;
improve memory, retrieval, reasoning, and document handling;
debug technical issues;
understand feature usage; and
improve internal coaching frameworks and research workflows.

We do not use identifiable Product health conversations or files to train public foundation models.

5.5 To Communicate With You

We use contact and account information to:

send waitlist, onboarding, account, security, product, and support messages;
respond to your questions;
send reminders or service notices;
request feedback from early users; and
send marketing communications only where permitted by law and your preferences.

You may opt out of non-essential marketing messages.

5.6 For Future Payment Processing

If paid features are introduced, we use billing information to issue invoices, manage paid access, handle refunds where applicable, prevent fraud, and comply with tax and accounting obligations.

5.7 To Meet Legal and Security Obligations

We may use information to:

enforce our Terms of Service;
detect abuse, spam, security incidents, or misuse;
comply with lawful requests, court orders, regulatory obligations, and tax/accounting rules;
preserve evidence in disputes; and
protect the rights, safety, and security of users, the public, FreeGym, Eureka, and Eureka Engine.

6. Legal Basis for Processing

Where a legal basis or lawful ground is required, we rely on the basis recognized by the law that applies to the relevant processing.

For users in India, this may include consent and other lawful or legitimate uses recognized under India's Digital Personal Data Protection framework and implementing rules, where applicable.

For users in the EU or UK, this may include consent, contractual necessity, legitimate interests, legal obligations, and any additional condition required for special category health data.

For users in other regions, the lawful basis may depend on local privacy, consumer protection, health-information, or data protection law.

In practical terms, we process information for:

waitlist signups, marketing opt-ins, sensitive health data, and optional sharing where consent is required or appropriate;
providing the Products, maintaining your account, responding to support requests, managing any paid access if introduced, and delivering features you request;
security, debugging, product reliability, abuse prevention, internal analytics, and service improvement, only where permitted by applicable law and not overridden by your privacy rights; and
tax, accounting, consumer protection, court, regulatory, or lawful government obligations.

For health data and other highly sensitive data, we do not rely on vague product-improvement interests as the main reason to collect it. The reason is the Product function you requested, your consent where required, safety, or legal necessity.

7. AI Processing and Human Access

7.1 AI Processing Is Necessary for the Products to Work

The Products are AI services. AI is a non-deterministic technology: it can produce different outputs from similar inputs, and it will be imperfect. The Products are intended to make organization, reflection, coaching support, and decision preparation easier, not to make decisions for you or replace human judgment. You are expected to use the Products responsibly, review their outputs, and avoid relying blindly on any response, memory, reminder, summary, recommendation, or safety check. To answer you, the system must process your messages, relevant memories, uploaded files, and context through model infrastructure. This means Product conversations are not end-to-end encrypted in the same way as a sealed private message between two humans. The system must be able to process the content to respond.

We protect that content through access controls, encryption in transit, encryption at rest where available, provider security controls, and limited human access.

7.2 Model Providers

We may use third-party AI model providers and infrastructure providers to generate responses, parse documents, summarize information, and run automated safety checks. We send only the information needed for the requested function where reasonably possible.

We do not permit model providers to use your identifiable Product conversations, health files, or memory to train their public models unless we first tell you and obtain any legally required consent.

7.3 Human Review

Our team does not routinely read private Product conversations or uploaded health files. Human access may occur only when:

you explicitly share a conversation, report, file, or link with us;
you request support that requires looking at the relevant content;
we need to investigate a safety, abuse, fraud, or security issue;
we need to debug a serious product failure and cannot do so with anonymized data;
we are legally required to review or disclose information;
you authorize us to prepare a summary or report for you to share with a coach, family member, clinician, or other person; or
you participate in a research, testimonial, case study, or feedback process with explicit consent.

When human access is necessary, we aim to limit it to the smallest amount of information needed.

We do not sell your personal data and do not disclose your identifiable health data for advertising. We may share information only as described below.

8.1 Service Providers

We use service providers and integrations for cloud hosting, authentication, database and file storage, security, AI model processing, analytics and reliability, notification delivery, weather/display features, and content delivery.

This includes providers for:

cloud hosting, databases, storage, authentication, and security;
AI model inference and document processing;
email, waitlist, and notification delivery;
invoicing and payment processing, if paid features are introduced;
analytics, logging, and reliability monitoring;
customer support and product feedback; and
legal, accounting, compliance, and professional services.

These providers may process information only for the services they provide to us, subject to their contracts and applicable law.

8.2 Other Users or the Public

If you choose to publish or share a Product conversation, summary, report, post, profile item, testimonial, or link, the audience you select may see it. Do not share private health information publicly unless you are comfortable with that audience seeing it.

8.3 Coaches, Clinicians, Family Members, or Caregivers

We do not share Product information with coaches, clinicians, family members, or caregivers unless you take a sharing action, such as:

directing us to make specific information available to a specific person;
creating and sharing a link or export; or
asking us to prepare a specific report or summary for you to share.

The Products do not route conversations, reports, or outputs to doctors, hospitals, emergency services, medical authorities, coaches, caregivers, or family members. We do not contact those people or services on your behalf. If either Product suggests outside help, you are responsible for contacting the appropriate person or service yourself. Separately, we may disclose information for legal, safety, and rights-protection reasons described below, such as in response to a valid court order, legal process, or government request.

8.4 Legal, Safety, and Rights Protection

We may disclose information if we believe disclosure is reasonably necessary to:

comply with law, court orders, subpoenas, legal process, or government requests;
enforce our Terms of Service;
investigate fraud, abuse, security incidents, or harmful conduct;
protect the rights, safety, or property of users, the public, FreeGym, Eureka, or Eureka Engine; or
establish, exercise, or defend legal claims.

These legal and safety disclosures are limited exceptions. They are not a Product feature for monitoring your conversations or routing you to medical care.

Where legally permitted and practical, we will try to notify you before disclosing your information in response to a legal request.

8.5 Business Transfers

If FreeGym, Eureka, Eureka Engine, or relevant assets are involved in a merger, acquisition, financing, reorganization, or transfer of operations, information may be transferred as part of that transaction. We will require the recipient to honor this policy or provide notice before materially different processing occurs.

9. Cookies, Website Technologies, and External Assets

The product websites may use essential browser storage, cookies, or similar technologies to operate the site, preserve interface state, improve performance, prevent abuse, or understand basic usage.

We may store drafts, recent conversation state, preferences, and interface state locally on your device or browser so the Product can restore your session and prevent data loss. Local copies may remain until you clear browser/app storage, sign out where clearing is supported, or delete the app.

The site may load external assets or public data from third parties, including Google Fonts, GitHub profile images, and public FreeGym-Wiki contributor data. When your browser requests third-party assets, those third parties may receive technical information such as your IP address, browser, and request time under their own policies.

We may use analytics, logging, and reliability tools to understand basic usage, improve performance, detect issues, prevent abuse, and protect the Products. We do not use Product health data for advertising, cross-context behavioral advertising, or ad targeting. If we add materially different tracking tools in the future, we will update this policy and provide consent or opt-out controls where required.

10. Health Privacy, Consumer Health Data, and Medical Records

This section includes U.S.-specific health privacy concepts, but the Products are not written only for U.S. users. Users in India, the EU, the UK, and other regions may have privacy, consumer protection, health-information, medical confidentiality, or AI-related rights under local law.

In the United States, the Products are generally a direct-to-consumer AI coaching service. Unless we enter into a specific written agreement with a HIPAA-covered entity or business associate, the Products are not acting as your doctor, health plan, hospital, or HIPAA business associate.

If you download a medical record from your doctor and upload it to either Product, the copy held by the relevant Product is governed by this Privacy Policy and applicable consumer privacy laws, not necessarily by your doctor's HIPAA notice.

For users in India, India's Digital Personal Data Protection framework, its implementing rules, and other applicable Indian laws may apply to digital personal data. For users in the EU or UK, health data may be treated as special category data. For users in other regions, local privacy and consumer health data laws may apply depending on where you live, where we operate, and how the Products are configured.

We treat health-related information as highly sensitive regardless of whether a particular law calls it health data, consumer health data, special category data, sensitive personal information, or ordinary personal data. Where applicable law gives you stronger or additional rights, this Privacy Policy does not limit those rights.

This does not make either Product a doctor, hospital, clinic, telemedicine service, medical device, health plan, HIPAA covered entity, or licensed healthcare provider in any country. If local law requires a licensed professional for diagnosis, treatment, prescription, emergency response, or clinical decision-making, you must use an appropriate licensed professional.

Depending on jurisdiction and product configuration, consumer health data laws and health breach notification laws may apply. If a breach involving your unsecured health information occurs, we will notify affected users and regulators as required by applicable law.

11. Data Retention

We keep information only as long as reasonably necessary for the purpose it was collected, unless a longer period is required by law, safety, dispute resolution, fraud prevention, or accounting obligations.

Typical retention periods:

Waitlist information: retained until you unsubscribe, request deletion, or the waitlist purpose expires. We may retain minimal suppression records to avoid contacting you again.
Account information: retained while your account is active and for a reasonable period after closure for security, legal, and operational needs.
Product conversations and memory: retained while your account is active so continuity works. You may request deletion, subject to legal, safety, and backup limitations.
Uploaded health files and reports: retained while needed for the Products, unless you delete them or request deletion.
Support and legal records: retained as needed to respond, resolve disputes, enforce terms, or comply with law.
Billing and tax records: retained for the period required by accounting and tax law, which may be up to 7 years or longer if legally necessary.
Backups: deleted or overwritten on a delayed schedule according to provider backup cycles.
De-identified or aggregated information: may be retained without identifying you.

If you ask us to delete information, we will delete or de-identify it unless we need to retain it for legal, security, accounting, dispute, or safety reasons.

12. Security

We use reasonable administrative, technical, and organizational safeguards designed for sensitive data, including:

HTTPS/TLS encryption in transit;
encryption at rest where supported by our cloud providers;
access controls and limited team access;
provider security controls from established cloud and infrastructure services;
account authentication and session controls;
monitoring for abuse and security incidents;
internal restrictions on handling health data; and
deletion or de-identification where appropriate.

No system is perfectly secure. AI services also require server-side processing, which means the content cannot be sealed from all processing infrastructure. You should not submit government ID numbers, financial credentials, passwords, or unrelated secrets unless a feature specifically requires them.

If you believe your account or data has been compromised, contact support@freegym.club immediately.

13. International Transfers

We may process and store information in India, the United States, and other countries where our service providers operate. These countries may have different data protection laws than your country.

When required, we use appropriate safeguards for cross-border transfers, such as contractual commitments, provider data processing terms, consent, or other lawful transfer mechanisms.

14. Your Choices and Rights

Depending on where you live, you may have rights to:

access the personal data we hold about you;
receive a copy of certain data in portable form;
correct inaccurate or incomplete data;
delete data;
withdraw consent;
object to or restrict certain processing;
opt out of marketing communications;
opt out of sale or sharing where applicable;
limit use of sensitive personal information where applicable;
appeal a decision about a privacy request where applicable; and
authorize another person to make a request on your behalf where law allows.

We will not discriminate against you for exercising privacy rights.

To make a request, email support@freegym.club with enough information for us to verify and process the request. We may ask for additional information to verify your identity and protect your account.

Withdrawing consent or deleting health data may limit or end the Products' ability to provide personalized coaching, memory, or continuity.

15. Regional Privacy Notices

If the California Consumer Privacy Act, other U.S. state privacy laws, the EU GDPR, the UK GDPR, India's Digital Personal Data Protection framework and implementing rules, or another privacy law applies to your data, we will handle privacy rights and obligations in accordance with that law.

For users in India, India's Digital Personal Data Protection framework and implementing rules may apply to digital personal data. Where applicable, you may have rights to access information about processing, correct or update inaccurate personal data, delete personal data, withdraw consent, use grievance redressal, and nominate or authorize another person where law allows. You may contact us at support@freegym.club. We aim to acknowledge privacy grievances within 72 hours and resolve them within a reasonable timeframe, generally within 30 days unless the issue is complex or the law requires another timeline.

For California residents, sensitive personal information may include health information, precise geolocation, genetic data, contents of communications, and other categories defined by law. We use sensitive personal information only to provide the Products, secure the Products, comply with law, and for other permitted purposes. We do not sell or share sensitive personal information for cross-context behavioral advertising.

For EU and UK users, health data may be special category data. Where required, we process it based on explicit consent, provision of the requested service, legal obligations, or other permitted grounds. You may have the right to lodge a complaint with your local data protection authority.

For users in other regions, we will honor applicable local privacy rights where those laws apply to the Products. Some rights depend on your location, our operational presence, the type of data, and the specific Product feature involved.

16. Children and Minors

The Products are not directed to children under 13.

Users under 18 may use the Products only with the active consent and supervision of a parent or legal guardian. A parent or guardian must accept this Privacy Policy and our Terms of Service on the minor's behalf.

Parents or legal guardians may provide information about a minor for family-care organization or coaching support, but only when they have legal authority to do so. We do not knowingly sell children's personal data, use children's health data for advertising, or knowingly engage in targeted advertising to children.

If you believe a child has provided data without proper consent, contact support@freegym.club and we will take appropriate action.

17. Marketing, Testimonials, and Public Examples

We will not use your private Product conversations, health files, lab reports, progress photos, name, likeness, or identifiable story for marketing without your explicit permission.

If you give a testimonial, participate in a case study, or approve a public example, we will use only the material you approved and only for the purposes described when you gave consent. You may withdraw consent for future use by contacting us, though already-published materials may take time to remove and may persist where others have copied or indexed them.

Demo conversations on the product websites are fictional or composite examples. They are not presented as private user data.

18. Changes to This Policy

We may update this policy as Eureka or Eureka Engine changes, as laws change, or as our providers and data practices evolve. When changes are material, we will update the "Last Updated" date and provide additional notice where required.

Your continued use of either Product after an updated policy becomes effective means you accept the updated policy, to the extent permitted by law. If you do not agree, you should stop using the Products and contact us about your data choices.

19. Contact

For privacy questions, rights requests, deletion requests, or grievances, contact:

FreeGym Support
support@freegym.club