ASENSEI SPARK — PRIVACY POLICY
Last updated 13th May 2026
1. Who We Are
ASENSEI Inc. (“ASENSEI”, “we”, “us”, “our”) is the data controller responsible for your personal data collected through the ASENSEI Spark application (“Spark app”). ASENSEI is a Delaware corporation based in the United States.
Contact:
ASENSEI Inc.
Email: ai.support@asensei.com
If you have questions about how we handle your data, or wish to exercise any of your rights described in this policy, contact us at the email address above.
2. About This Policy
This Privacy Policy explains what personal data we collect when you use the Spark app, why we collect it, how we use and protect it, and what rights you have. This policy applies to the Spark app only. Other ASENSEI products (such as asensei rowing) may have their own privacy disclosures.
This Privacy Policy should be read alongside the ASENSEI Spark Terms of Use and the ASENSEI Terms of Service.
3. What Data We Collect
We collect the following categories of data when you use the Spark app:
3.1 Account Data
When you create an account, we collect:
- Name
- Email address
- Password (stored in hashed form)
If you use the Spark app as a guest, we do not collect Account Data.
3.2 Movement Data
When you use the Spark app’s camera-based features, the ASENSEI SDK processes your camera feed on your device in real time to generate Movement Data. Movement Data consists of skeletal joint positions, angles, and movement patterns derived from the camera feed.
The camera feed is processed on your device and discarded in real time — it is not stored or transmitted for the purpose of generating Movement Data. However, when video recording is enabled for your Program (see Section 3.3), the camera feed is recorded and uploaded to ASENSEI Cloud.
Movement Data is synced to ASENSEI Cloud (hosted on Amazon Web Services in the United States).
3.3 Video Recordings
Depending on the Program you are using, the Spark app may record video of your exercise sessions. Video recording is controlled by Program settings and may be enabled or disabled in your app settings where available. When video recording is enabled, video is uploaded to ASENSEI Cloud.
When you use the Spark app as a guest (without a subscription), video recording is not enabled.
3.4 Session Results
Data generated from your exercise sessions, including repetition counts, joint angles, movement nuances, scores, and progress tracking. Session Results are processed on your device and synced to ASENSEI Cloud.
3.5 Session Logs
Technical log files generated during exercise sessions, used for diagnostics, troubleshooting, and service improvement. Session Logs are synced to ASENSEI Cloud.
3.6 Device and Usage Data
We collect limited technical data about your device and how you use the Spark app, including:
- Device type and operating system
- App version
- App usage patterns (features used, session frequency)
- Crash reports and error logs
- IP address (collected automatically by our servers and third-party services)
This data is collected through our analytics and crash reporting tools (see Section 6).
3.7 Payment and Billing Data
If you subscribe to a paid Program, your subscription is purchased and managed through the ASENSEI website (asensei.com), not through the Spark app. During this process, we collect:
- Billing name and address
- Payment card details (processed and stored by Shopify — ASENSEI does not directly store your full card number)
- Transaction history and subscription status
Shopify processes your payment data in accordance with their own privacy policy. ASENSEI receives confirmation of your subscription status, transaction history, and billing address from Shopify.
4. How We Use Your Data
We use your data for the following purposes:
| Purpose | Data used | Legal basis (GDPR) |
|---|---|---|
| Providing real-time movement coaching and analysis | Movement Data, Session Results | Performance of contract |
| Delivering Programs (free and paid) | Account Data, Movement Data, Session Results, Video Recordings | Performance of contract |
| Creating and managing your account | Account Data | Performance of contract |
| Processing subscriptions and payments | Account Data, Payment Data (via Shopify) | Performance of contract |
| Diagnosing technical issues and improving the Spark app | Session Logs, Device and Usage Data | Legitimate interests |
| Crash reporting and error monitoring | Device and Usage Data, Session Logs | Legitimate interests |
| Analytics — understanding how the Spark app is used | Device and Usage Data | Legitimate interests |
| Research, product improvement, and coaching model development (using anonymised and aggregated data only) | Anonymised Movement Data and Session Results | Legitimate interests |
| Communicating with you about your account or subscriptions | Account Data | Performance of contract |
| Sending marketing or promotional communications | Name, Email address | Legitimate interests (with opt-out) |
| Complying with legal obligations | As required | Legal obligation |
We may use your name and email address to send you marketing or promotional communications about ASENSEI products and services. You can opt out of marketing communications at any time by using the unsubscribe link in any email or by contacting ai.support@asensei.com. We do not sell your personal data to third parties.
5. Movement Data and Biometric Information
5.1 What Movement Data Is
Movement Data consists of skeletal joint positions, angles, and movement patterns derived from your camera feed during exercise sessions. The camera feed is processed on your device by the ASENSEI SDK in real time to generate Movement Data. The camera feed is discarded after processing unless video recording is enabled for your Program (see Section 3.3).
5.2 Movement Data Is Not Used for Identification
ASENSEI does not use Movement Data for personal identification, facial recognition, biometric authentication, or surveillance of any kind. No biometric templates are created for the purpose of identifying individuals. Movement Data is collected and processed solely for the purpose of coaching, form analysis, and exercise tracking.
5.3 US Biometric Privacy Laws
Some US states (including Illinois, Texas, and Washington) have laws that regulate the collection and use of biometric information. While ASENSEI does not use Movement Data as a biometric identifier, we take these laws seriously and apply the following practices regardless of where you are located:
- We disclose what Movement Data we collect and why (this policy and the Spark Terms of Use)
- We obtain your consent before accessing your camera (via your device’s permission prompt)
- We do not sell, lease, or trade Movement Data. Movement Data may be shared with Program Partners as part of a partner agreement to deliver the service you have subscribed to (see Section 6.1)
- We delete Movement Data within 30 days of account deletion or upon request
- We use reasonable security measures to protect Movement Data
6. Who We Share Your Data With
6.1 Program Partners
When you subscribe to a Program delivered by or in conjunction with a Program Partner (such as Kinaxa, Proof3, or InMotion Wellness Studios), your Movement Data, Session Results, and, where applicable, video recordings may be shared with that Program Partner to deliver the service.
Each Program’s terms identify the Program Partner and describe what data is shared. Once your data has been shared with a Program Partner, that Program Partner is independently responsible for their handling of your data under their own privacy policy.
6.2 Third-Party Service Providers
We use the following third-party services in connection with the Spark app:
| Service | Purpose | Data shared |
|---|---|---|
| Amazon Web Services (AWS) | Cloud hosting and data storage (ASENSEI Cloud) | All data synced to ASENSEI Cloud |
| Heroku (Salesforce) | Server-side processing, upload handling, and data analysis | Movement Data, Session Results, Session Logs |
| Sentry | Crash reporting and error monitoring | Crash reports, error logs, device information |
| Google Analytics | Website and app analytics | Usage patterns, device type, IP address (anonymised) |
| Shopify | Payment processing for subscriptions | Payment and transaction data |
These service providers process data on our behalf and are contractually required to protect your data. They do not receive your Movement Data, Session Results, or video recordings, except for AWS (which hosts ASENSEI Cloud) and Heroku (which processes uploads and analysis), as described in the table above.
6.3 Legal and Safety Disclosures
We may disclose your data if required to do so by law, or if we believe in good faith that disclosure is necessary to:
- Comply with a legal obligation, court order, or legal process
- Protect the rights, property, or safety of ASENSEI, our users, or the public
- Detect, prevent, or address fraud, security, or technical issues
6.4 Business Transfers
If ASENSEI is involved in a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your data.
7. International Data Transfers
ASENSEI Inc. is based in the United States. Your data is stored and processed on servers located in the United States (Amazon Web Services and Heroku). ASENSEI also has a UK entity, but data collected through the Spark app is processed in the United States. If you are located outside the United States (including in the European Economic Area or United Kingdom), your data will be transferred to and processed in the United States.
The United States may not provide the same level of data protection as your home country. By using the Spark app, you consent to the transfer of your data to the United States. Where required by applicable law (including GDPR), we will ensure appropriate safeguards are in place for international data transfers, such as Standard Contractual Clauses.
8. How Long We Keep Your Data
| Data type | Retention period |
|---|---|
| Account Data | Retained while your account is active; deleted within 30 days of account deletion or request |
| Movement Data | Retained while your account is active; deleted within 30 days of account deletion or request |
| Video Recordings | Retained while your account is active; deleted within 30 days of account deletion or request |
| Session Results | Retained while your account is active; deleted within 30 days of account deletion or request |
| Session Logs | Retained while your account is active; deleted within 30 days of account deletion or request |
| Device and Usage Data | Retained for up to 26 months (in line with analytics provider defaults) |
| Billing and Transaction Records | Retained for up to 24 months after account deletion (for tax, legal, and dispute resolution purposes) |
Guest users: if you use the Spark app without creating an account, we do not retain personal data beyond your session. Device and Usage Data may still be collected by analytics services as described in Section 6.2.
9. Your Rights
Depending on where you are located, you may have the following rights regarding your personal data:
9.1 Rights Available to All Users
- Access — You can request a copy of the personal data we hold about you
- Deletion — You can request that we delete your personal data. Contact ai.support@asensei.com. We will delete your data within 30 days, except for billing records we are required to retain (see Section 8)
- Correction — You can request that we correct inaccurate personal data
9.2 Additional Rights for EEA and UK Residents (GDPR)
If you are located in the European Economic Area or United Kingdom, you also have the right to:
- Restrict processing — Request that we limit how we use your data in certain circumstances
- Data portability — Request your data in a structured, commonly used, machine-readable format
- Object to processing — Object to our processing of your data where we rely on legitimate interests as our legal basis
- Withdraw consent — Where we process your data based on consent, you can withdraw that consent at any time (this does not affect the lawfulness of processing before withdrawal)
- Lodge a complaint — You have the right to lodge a complaint with your local data protection authority (e.g., the ICO in the UK, or the relevant authority in your EU member state)
9.3 California Residents (CCPA/CPRA)
If you are a California resident, you have the right to:
- Know what personal information we collect, use, and disclose
- Request deletion of your personal information
- Opt out of the sale of your personal information — ASENSEI does not sell your personal information
- Non-discrimination — We will not discriminate against you for exercising your rights
To exercise any of these rights, contact ai.support@asensei.com. We will respond within the timeframes required by applicable law (30 days for GDPR, 45 days for CCPA).
10. Children’s Data
The Spark app is not directed at children under 13. We do not knowingly collect personal data from children under 13. If you are between 13 and 18, you must have your parent or guardian’s consent to use the Spark app (as set out in the Spark Terms of Use).
If we become aware that we have collected personal data from a child under 13 without parental consent, we will take steps to delete that data promptly. If you believe a child under 13 has provided us with personal data, contact ai.support@asensei.com.
11. Security
We use reasonable technical and organisational measures to protect your personal data, including:
- Encryption of data in transit (TLS/SSL)
- Encryption of data at rest on ASENSEI Cloud
- Access controls limiting who within ASENSEI can access your data
- Regular security reviews of our infrastructure
No method of transmission or storage is completely secure. While we strive to protect your data, we cannot guarantee absolute security.
12. Cookies and Tracking
The Spark app itself does not use cookies. The ASENSEI website (asensei.com), which you may use to manage your subscription, uses cookies and similar technologies for site functionality and analytics. Details of website cookies will be provided on asensei.com.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be notified through the Spark app or by email. Your continued use of the Spark app after changes take effect constitutes acceptance of the updated policy.
We encourage you to review this policy periodically. The “Last updated” date at the top indicates when the policy was last revised.
14. Contact Us
If you have questions about this Privacy Policy or wish to exercise your data rights, contact us at:
ASENSEI Inc.
Email: ai.support@asensei.com
If you are located in the EEA or UK and are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.