Silverfern Ventures Pty. Ltd. Privacy Notice:

1. Scope of this Notice

This Privacy Notice explains how Silverfern Ventures Pty. Ltd. (“we,” “us,” “our”) collects, uses, and shares personal data when you:

• use Gains (“the App”) as a customer or user;
• interact with us on social media; or
• interact with us as a business contact.

This Notice does not apply to:

• our own employees, contractors, or job applicants;
• information that doesn't identify or relate to a specific person; or
• other websites or services we link to but don't control. Check their own privacy notices separately.

2. Who is responsible for your data

Silverfern Ventures Pty. Ltd. (ACN: 693101754) headquartered in Victoria, Australia, is the entity responsible for deciding how and why your personal data is processed through the App.

Contact us with questions at silverfernventuresptyltd@gmail.com.

3. What we collect

We collect the following categories of personal data.

• Account information: [e.g. name, email, date of birth] — required to create an account.
• Technical and usage information: any device type, log data, usage information and how you interact with the Platform, collected automatically.
• Payment information: All purchases are processed directly through the Apple App Store and/or Google Play billing systems. We do not receive, see, or store any payment or card details. Payment is handled entirely by Apple and Google under their own privacy and payment terms.
• Communications: anything you send us directly (e.g. support requests, emails etc.).
• Voluntary information: anything you choose to type into free-text fields (e.g. reviews, feedback, surveys etc.).

4. Why we use your data

We use personal data to:

• create and secure your account, and provide the features you sign up for;
• respond to your questions and provide support;
• maintain and improve the Platform, including basic usage analytics;
• fulfil our service of providing workout and recovery estimates and guides based on your specific physical attributes, experience, goals and daily alterations;
• meet legal obligations (e.g., confirming you meet the minimum age to use the Platform); and
• detect and prevent fraud, abuse, or security incidents.

We only use data for purposes beyond this list if we tell you first and, where required, get your consent.

5. Legal bases

Where required, we rely on one of the following legal bases to process your data:

• Contract — to provide the service you signed up for.
• Legal obligation — e.g., age verification.
• Legitimate interests — e.g., basic product analytics and security, balanced against your rights.
• Consent — e.g., for marketing emails or any sensitive data category.

You can withdraw consent at any time; this won't affect processing that already happened.

6. Security and retention

Security: We take reasonable technical and organisational steps to protect your personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. This includes:

• Restricting internal access to production data to personnel who require it to perform their role, on a need-to-know basis
• Relying on the security infrastructure provided by our service providers, including Apple Inc. (for data processed through the App Store, iCloud, or related Apple frameworks) and Supabase (for in-app data storage), both of which maintain their own industry-standard security measures, encryption, and compliance certifications

Retention: We keep personal data only as long as needed for the purposes it was collected for — generally, for as long as your account stays open, plus a reasonable period afterward for legal, accounting, or dispute-resolution reasons.

7. Where your data is stored

Your data is stored and processed via Supabase, with our primary database being based in Oceania (Sydney, Australia).

Some data may also be processed by third-party service providers located outside Australia, including Apple Inc. (United States) for App Store transactions and account services, and analytics/crash reporting/email providers for quality, maintenance and business development purposes.

Where personal information is disclosed to overseas recipients, we take reasonable steps to ensure it is handled consistently with the Australian Privacy Principles, including relying on these providers' own compliance frameworks and contractual data protection commitments (such as Apple's Data Processing Agreement and Supabase's Data Processing Agreement).

8. Who we share data with

We may engage additional service providers over time, for example, for analytics, marketing, or product insights — to help us operate and improve our product. Any new provider will be used only for purposes consistent with this policy, and we will update this privacy policy to reflect any material changes. Where required by law, we will seek your consent before using a new category of service provider or purpose. We currently share data with:

We may also share data:

• with government or law enforcement bodies where legally required;
• with professional advisers (lawyers, auditors) to protect our legal rights; and
• with a buyer if we sell or restructure our business, under confidentiality obligations, solely to evaluate or complete that transaction.

9. Your rights

Subject to your local law, you may have the right to:

• ask what data we hold about you and why (“access”);
• ask us to correct inaccurate data;
• ask us to delete your data;
• object to certain processing, including direct marketing;
• ask us to restrict processing while a dispute is resolved;
• request a portable copy of your data; and
• withdraw consent at any time, where consent is the basis for processing.

To exercise any of these, contact us at silverfernventuresptyltd@gmail.com. We may ask you to verify your identity first. You can also complain to your local data protection regulator [— e.g., the OAIC in Australia] if you're not satisfied with our response.

10. Links to other sites

The Platform may link to third-party websites we don't control. We're not responsible for their content or privacy practices — check their own policies.

11. Changes to this Notice

We may update this Notice from time to time. Updates take effect once posted within the app. We encourage you to review this Notice periodically. Your continued use of the App after changes take effect constitutes acceptance of the updated Notice.

12. Contact us

Questions, feedback, or rights requests: silverfernventuresptyltd@gmail.com.

13. Health related information.

We collect health-related information (e.g. height, weight, workout data etc.) when you choose to enter it. This is sensitive data under most data protection laws, so:

• providing it is always optional, though some core features (e.g. weight estimates and workout recommendations) won't work without it;
• we ask for your explicit consent where required by law, and you can withdraw it any time;
• we don't infer additional health information beyond what you've told us, or beyond providing workout estimates based on your provided information.

14. Referral Program

If you refer someone or are referred, we may connect that relationship (e.g., to apply a referral bonus) and let the referrer know their friend joined.

15. Marketing.

We may work with various advertising/analytics partners throughout the course of conducting our business. Depending on how data flows to them, this may count as a “sale” or “share” under US state privacy laws (like the CCPA), even though no money changes hands. If this applies to you and on the App onboarding you agreed to receive marketing communications: navigate to in-App settings page and toggle the off button for “I consent to receive marketing materials”.