Last updated 1 October 2026

Privacy Policy

BLACK ROCK HOLDINGS NSW PTY LTD ACN 634 422 236 (Programr, we, us, our) is committed to protecting your privacy. This policy explains what personal information we collect through the Programr iOS, watchOS and Android apps and programr.app (the App), why, who we share it with, and the controls you have.

This policy complies with the Privacy Act 1988 (Cth) (the Act) and the Australian Privacy Principles (APPs).

1. The short version

• On AI Coaching, your training programs and weekly progression are generated by OpenAI. To do that, we send OpenAI your training profile and training history. We do not send your name or email address.
• On Human Coaching, your coach can see your profile, your training and your messages, so they can coach you.
• We never sell your data, and we never use your training or health information for advertising.
• You can delete your account and all your data from inside the App at any time.

2. Information we collect

Account information. Your email address and name as provided by Sign in with Apple or Sign in with Google, and the account identifier Apple or Google gives us. We never see your Apple or Google password. If you use Apple's Hide My Email, we only receive the relay address. If you sign in with your email address, we store your email address and a securely hashed version of your password, never the password itself.

Training profile. Date of birth, gender, height, training experience, primary goal or event, days per week, session length, training location, available equipment, any injuries or limitations you tell us about, and any free-text comments you add.

Training data. Your programs, workouts, exercises, sets, reps, weights, rest times, personal records, notes, and the comments you give when finishing a week.

Body metrics. Bodyweight and any other measurements you choose to log.

Apple Health data. If you turn it on for your momentum score, your daily step count, your time asleep, and the workouts other apps save to Apple Health. Nothing else is read from Apple Health.

Coaching information. If you are on Human Coaching: which coach you chose, your messages with your coach, the requests you send them, and, if you link Discord, your Discord user ID and username.

Leaderboard information. If you opt in, your display name and lift results.

Support information. Anything you send us when you contact support or make a complaint.

Technical information. Device type, operating system and app version, and error logs needed to keep the App working.

Install and purchase measurement. When you install the App and when you subscribe, Google Analytics for Firebase and the Meta SDK record that event, and when you open the App, with an app-instance identifier and basic device information, so we can tell which of our ads work. On iPhone we do not ask to track you and do not collect the advertising identifier. See section 9.

Payment information. Purchases are handled entirely by Apple through the App Store or by Google through Google Play. We do not receive or store your card details. Apple or Google tells us only which subscription you have and whether it is active.

3. Health information

Some of the above is "health information" under the Act and is given extra protection. This includes your injuries, height, bodyweight and measurements, steps, sleep and workouts if you log or sync them, training history, and anything about your health you put in comments or messages to your coach.

We collect health information only with your consent and only to provide the App to you, including sharing it with your coach if you are on Human Coaching. You can use the App without giving us injury details, steps, sleep or body measurements, but your programs will be less tailored and there will be no momentum score.

4. How we use OpenAI

On the AI Coaching plan, Programr uses OpenAI's API to generate your training programs and to suggest progression each week. No person at Programr reviews a program before you receive it.

On the Human Coaching plan, your coach writes and updates your program, and your weekly feedback goes to your coach, not to OpenAI. If your coach uses the App's AI tools to draft part of your program, the information below is sent to OpenAI in the same way, and your coach reviews the result before you receive it.

What we send to OpenAI:

• When generating a program: your age, gender, training experience, goal, days per week, session length, training location, bodyweight, height, available equipment, injuries or limitations, and comments.
• When you finish a week: that week's workouts as you logged them (exercises, sets, reps, weights, rest times), your recent program history, and your comments on how the week went.

What we do not send to OpenAI: your name, email address, account identifiers, anything read from Apple Health (steps, sleep, workouts), your messages with your coach, or payment information.

Free-text fields. Your injury notes, comments and weekly feedback are sent to OpenAI exactly as you write them. We do not review or filter them before they are sent. Please do not include your name, contact details, or any other information that identifies you or another person.

If you choose to include personal information in these fields, you consent to it being disclosed to OpenAI in the United States so that it can generate and adjust your program. Before you give that consent, we expressly inform you that, under Australian Privacy Principle 8.2(b), if you consent, APP 8.1 will not apply to that disclosure. This means we will not be required to take reasonable steps to ensure OpenAI handles that information in accordance with the Australian Privacy Principles, and if OpenAI mishandles it, you may not be able to seek redress under the Privacy Act.

OpenAI is based in the United States. Under OpenAI's API terms, data sent through the API is not used to train OpenAI's models by default. OpenAI's handling of this data is governed by its own privacy policy and API data usage policies.

By creating a program in the App, you consent to the information above being disclosed to OpenAI in the United States for this purpose. If you do not consent, do not generate a program.

5. Human Coaching

What your coach sees. Your coach can see your name, email address, training profile (including injuries, goals and events), bodyweight, programs, logged training, notes, weekly feedback, requests and your chat with them. Your coach cannot see your Apple Health data or your payment details.

Other coaches. Our other coaches can also see this information, so they can look after you when your coach is away or unavailable, or if you switch coach. Your chat stays with your account, so a new coach can read your history.

Who coaches are. Coaches are our employees or contractors. They may use your information only to coach you, and they are bound to keep it confidential.

Emails. When you message your coach, finish a week or send a request, we email your coach to let them know, including your comments. When your coach messages you, we may email you. These emails are sent through our email provider, Resend.

Discord. Linking Discord is optional. If you link it, Discord tells us your Discord user ID and username, and we add you to our coaching community with a role. Other members of the community can see your Discord profile and anything you post there. We never post your training data to Discord. Discord is based in the United States and handles your information under its own privacy policy. When your Human Coaching plan ends, or you delete your account, we remove your role.

6. Apple Health data

Reading from Apple Health is off until you turn it on in the App's Metrics screen, and reads only your daily steps, your sleep, and the workouts other apps save there (a run, a class). We use them only to work out and show your momentum score. We do not use them for advertising, we do not sell them, and we do not share them with third parties, with your coach or with OpenAI. You can turn Apple Health access off at any time in the App or in iOS Settings.

7. Leaderboards

Leaderboards are off by default. If you turn them on, other Programr users can see your display name and your best lifts for the exercises shown. You can turn this off at any time in the App and your entries are removed.

8. How we use your information

We use your information to:

1. create and maintain your account;
2. generate your training programs and weekly progression through OpenAI, on AI Coaching;
3. let your coach write and update your program, message you, and run the coaching community, on Human Coaching;
4. record, display and analyse your training, progress and personal records;
5. sync your data between your devices;
6. run leaderboards if you opt in;
7. manage your subscription status;
8. measure which of our ads lead to installs and subscriptions;
9. respond to support requests and complaints;
10. keep the App secure and fix problems; and
11. send you service messages about your account, your coaching, or changes to this policy.

We do not sell your personal information, and we do not use your training or health information for advertising.

9. Who we share it with

We share personal information only with:

• OpenAI, as described in section 4;
• our coaches, if you are on Human Coaching, as described in section 5;
• Discord, only if you link your Discord account, as described in section 5;
• Apple and Google, to sign you in and to process purchases;
• Google, through Google Analytics for Firebase, which receives install and subscription events with an app-instance identifier and basic device information, so we can measure our Google ads. It does not receive your name, email address, training or health information;
• Meta (Facebook and Instagram), through the Meta SDK, which receives install, app-open and subscription events with an app identifier and basic device information (and, on Android, the advertising ID), so we can measure our Meta ads. It does not receive your name, email address, training or health information;
• Resend, our email provider, to send your account and coaching emails;
• our hosting and infrastructure providers, including Cloudflare, who store and transmit data on our behalf and may not use it for their own purposes; and
• anyone we are required to disclose it to by law.

10. Where your information is stored

Your data is stored on servers located in Australia. Information sent to OpenAI, Discord, Resend and Google may be processed in the United States. Some of our infrastructure providers may process data in other countries. We take reasonable steps to ensure overseas recipients handle your information consistently with the APPs.

11. How we protect it

We take reasonable steps to protect your information from misuse, loss and unauthorised access, including encrypting data in transit, restricting database access to authorised people, limiting coaches' access to clients on a coaching plan, and keeping backups.

If a data breach is likely to cause you serious harm, we will notify you and the Office of the Australian Information Commissioner (OAIC) as required by the Notifiable Data Breaches scheme.

12. Retention and deleting your account

We keep your information while your account is active. You can delete your account at any time in the App under Profile > Delete account, or by emailing us (see programr.app/delete-account). When you do, we delete your personal information within 30 days, including your messages with your coach, and remove your role in our Discord community, except anything we must keep by law. Messages you posted on Discord are held by Discord, and you can delete them there.

If your account is inactive for more than 24 months, we may delete it after emailing you first.

13. Access and correction

Most of your information can be viewed and edited in the App. You can also ask us for a copy of the personal information we hold about you, or ask us to correct it, by emailing [email protected]. We will respond within 30 days.

14. Anonymity

You can use a pseudonym as your display name. Because you sign in with Apple, Google or an email address, you cannot use the App fully anonymously, but Apple's Hide My Email keeps your real email address from us.

15. Children

The App is for people aged 18 and over. We do not knowingly collect information from anyone under 18. If we learn we have, we will delete it.

16. Complaints

If you have a complaint about how we have handled your personal information, email [email protected]. We will respond within 30 days. You may complain anonymously, though that may limit what we can do.

If you are not satisfied with our response, you can complain to the OAIC.

17. Contact

Email: [email protected]
Post: The Privacy Officer, BLACK ROCK HOLDINGS NSW PTY LTD, 11 Wembley Road, Moss Vale NSW 2577

18. Changes to this policy

We may update this policy from time to time. We will notify you in the App or by email. Changes take effect for new users on posting, and for existing users 7 days after we notify you. If you do not agree to an updated policy, you can delete your account.