Privacy Policy

Last Updated: March 5, 2026

FREE60 ("we," "our," or "us") operates the FREE60 mobile application (the "App"). This Privacy Policy explains how we collect, use, store, and protect your information when you use the App.

By using the App, you agree to the collection and use of information in accordance with this policy.

1. Information We Collect

1.1 Account Information

When you create an account, we collect:

• Email address
• Authentication credentials (managed by Firebase Authentication)
• Account preferences and settings

1.2 Health and Fitness Data

With your explicit permission, we access the following data from Apple Health (HealthKit):

• Sleep analysis (duration, stages, consistency)
• Heart rate and heart rate variability (HRV)
• Resting heart rate
• Activity data (steps, active energy, exercise minutes, stand hours)
• Respiratory rate
• Blood oxygen saturation

We never access health data without your explicit authorization through the iOS Health permissions dialog. You may revoke access at any time through your device's Settings > Health > Data Access & Devices.

1.3 User-Entered Data

You may manually enter data into the App, including:

• Nutrition targets and protein intake logs
• Financial data (income, expenses, investment allocations, liquidity)
• Care and screening schedules
• Time allocation, workflow, and boundary configurations
• Reflection and practice logs

1.4 Calendar Data

With your explicit permission, we may access calendar event data to auto-fill time allocation entries. Calendar data is processed locally on your device and is not transmitted to our servers.

1.5 Device and Usage Data

We collect standard analytics data including:

• Device type and operating system version
• App version
• Crash reports and performance data
• Feature usage patterns (anonymized)

2. How We Use Your Information

We use your information exclusively to:

• Calculate KPI scores across three dimensions (Health, Wealth, Capacity)
• Generate your Freedom Index score
• Provide personalized AI-generated insights based on your data patterns
• Detect cross-dimensional signals (e.g., sleep patterns affecting other areas)
• Store your configuration, targets, and historical logs
• Improve App stability and performance

We do not use your data for:

• Advertising or ad targeting
• Selling to third parties
• Building marketing profiles
• Population-level research (unless explicitly anonymized and consented to in the future)

3. AI Features and Data Processing

The App includes AI-powered features that generate insights from your data. When AI features are used:

• Your aggregated scores and trends may be sent to third-party AI providers (currently OpenAI) to generate text-based insights
• We send the minimum data necessary: dimension scores, trend direction, and score changes. We do not send raw health readings, financial amounts, or personally identifiable information to AI providers
• AI-generated content is for informational purposes only and does not constitute medical, financial, or professional advice

4. Data Storage and Security

4.1 Where Data Is Stored

• Account data, scores, and logs: Google Cloud Firestore (Firebase), hosted in the United States
• Health data from HealthKit: Processed on-device. Aggregated scores (not raw readings) are stored in Firestore
• Calendar data: Processed entirely on-device. Never transmitted to our servers
• Authentication: Managed by Firebase Authentication with industry-standard encryption

4.2 Security Measures

• All data in transit is encrypted using TLS 1.2 or higher
• Firestore security rules enforce per-user data isolation; users can only read and write their own data
• Firebase Authentication tokens expire and rotate automatically
• We do not store passwords; authentication is handled by Firebase's secure infrastructure

4.3 HealthKit Compliance

In accordance with Apple's HealthKit guidelines:

• Health data is never used for advertising or marketing
• Health data is never sold, shared with data brokers, or disclosed to third parties for purposes unrelated to providing health services to you
• Health data is not stored in iCloud by the App
• We use health data solely to provide the core functionality of the App (KPI scoring and insights)

5. Data Sharing

We do not sell your personal information. We share data only in the following limited circumstances:

• Service Providers: Firebase (Google) for authentication and data storage; OpenAI for AI insight generation (aggregated scores only, no PII)
• Legal Requirements: If required by law, court order, or governmental authority
• Safety: To protect the rights, property, or safety of FREE60, our users, or the public
• Business Transfer: In the event of a merger, acquisition, or asset sale, your data would be transferred to the successor entity under the same privacy protections

6. Data Retention

• Your data is retained as long as your account is active
• If you delete your account, we will delete your personal data from our systems within 30 days
• Anonymized, aggregated data that cannot be linked to you may be retained for product improvement
• Backups may retain deleted data for up to 90 days before automatic purging

7. Your Rights

You have the right to:

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of inaccurate data
• Deletion: Request deletion of your account and all associated data
• Portability: Request your data in a machine-readable format
• Withdraw Consent: Revoke HealthKit or calendar permissions at any time through device settings
• Opt Out of AI: Disable AI-powered features within the App settings

To exercise any of these rights, contact us at [email protected].

8. Children's Privacy

The App is not intended for children under 16. We do not knowingly collect personal information from children under 16. If we discover that a child under 16 has provided us with personal data, we will delete it promptly.

9. International Users

The App is currently available in the United States. If you access the App from outside the United States, your data will be transferred to and processed in the United States. By using the App, you consent to this transfer.

For users in the European Economic Area (EEA), United Kingdom, or other jurisdictions with data protection laws, we process your data on the legal bases of:

• Consent: For health data access and AI features
• Contract: For providing the App's core functionality
• Legitimate Interest: For security, fraud prevention, and product improvement

10. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted in the App and on our website. The "Last Updated" date at the top reflects the most recent revision. Continued use of the App after changes constitutes acceptance of the revised policy.

11. Contact

If you have questions about this Privacy Policy:

• Email: [email protected]
• Website: https://free60.app/privacy