Last updated: February 4, 2026
This Privacy Notice is to inform you, as a user of the RETURN app and/or related website (further the 'App' and the 'Website' respectively, together 'we/us', the 'Product'), on the processing of your personal data in connection with the use of the Product.
When we say "personal data" or "personal information", we are referring to information related to you. Such information is not limited to what directly identifies you, such as your name. In fact, you own and have legal rights to anything that speaks of you: the data you enter about your fitness experience, your aim for using the Product, even the way you use the Product itself. To avoid legalese, we can also use "your data" or "your information" in the same meaning.
This notice is meant to provide you with all relevant information to make an informed choice to use the Product. It also serves to inform you of your rights and how you can exercise them. Contact us if you have any questions or concerns.
In order to provide you with our Product, we have launched it as a Website and as an App.
In any scenario, the controller responsible for your data is Funplex Limited, with its registered address at Karaiskaki 13, 3032, Limassol, Cyprus. You may contact Funplex via these contact points.
Should you have any general questions about this Privacy Notice, the use of your data by us, or if you want to assert your data protection rights, please use the following email address:
hello@wproductlab.com
Please note that in some cases, for your safety and when we have reasonable concerns about the authenticity of a request, we may need to authenticate you before proceeding with your request.
You are entitled to data-related rights as described below. You may assert them directly via the App (to the extent possible) or via the contact options above.
Please note that these rights are based on European laws, namely the General Data Protection Regulation (the "GDPR"). Depending on your country of residence, those rights may have different interpretations. Should you wish to assert your country-specific rights, kindly let us know, and we will review your case individually.
You may ask to confirm whether we process your data and if so, to provide you with the scope of such processing and a copy of the data concerning you stored by us.
You have the right to request correction of inaccurate personal data concerning you and the completion of incomplete data. We try to allow you to correct/add data through the Product's settings to the extent possible, e.g. you can log in to your user profile and correct, amend, or delete information about yourself. We will also inform third parties to whom we transferred your data in the event of rectification of your data.
You may request the erasure of your personal data stored by us. Please note, however, that the right to erasure is not absolute and shall be fulfilled by us only provided specific legal requirements are met. You may request data erasure only if:
Further, your right to erasure is subject to restrictions. For example, we are not under obligation or even allowed to delete data that we are still obligated to retain due to statutory retention periods. Similarly, data that we need for the establishment, exercise, or defense of legal claims is excluded from your right to erasure.
If we have transferred personal data to third parties, we will either initiate the deletion of your data from such third parties or inform them about the erasure, insofar as required by applicable law.
In order to avoid any unnecessary legalese and keeping in mind the general use of such words, we will interpret all user requests asking us to "delete my data" as requests for erasure of data under Article 17 GDPR.
You have the right to request, under certain conditions, restriction of processing (i.e. the marking of stored personal data to restrict its future use). The requirements for restriction of processing are as follows:
You have the right to object to the processing of your personal data in whole or in part at any time, and in any form, in the event that our processing is based on a legitimate interest (balancing of interests). In order to process your objection, we kindly request you to refer to your particular situation as to why you believe that your rights and freedoms are at a particular risk (see Article 21 of GDPR for more details).
Please note that the right to objection is not absolute, and we will stop the processing of your data only provided we cannot demonstrate compelling legitimate grounds for processing.
Where the processing you object against concerns direct marketing purposes, we will stop any processing once we receive an objection from you. A common example of how you can exercise an objection to marketing communications is pressing the "unsubscribe" button in emails.
You have the right to receive the data you provided to us in a commonly used and machine-readable format to transfer that data to another controller without our interference.
To the extent possible, we will allow you to export data for further use directly via the App. You may also ask us to assist you with moving your data where it is technically feasible. Please note that this option relates only to data processed based on the performance of our contract with you or based on your consent. For more information about the contract and consent, please refer to Section 5 below.
If you provide consent to the processing of your personal data, you can withdraw it at any time. Consent withdrawal does not have a retroactive effect, meaning that any processing which occurred before the withdrawal shall not be affected.
You can lodge a complaint with the data protection authority at any time if you believe that your data has been processed unlawfully. Here is the contact information for the supervisory data protection authority:
Data Protection Commissioner, 1 Iasonos Street, 1082 Nicosia, Cyprus, tel: +357 22818456, fax: +357 22304565, email: commissioner@dataprotection.gov.cy
In this Section, you can find a description of your privacy rights as a California resident, which are established under California laws, such as the California Consumer Privacy Act (the "**CCPA**").
Please note that in this Section 3.1, we describe California-specific rights that substantially differ from those established under the GDPR. These rights are in addition to those established under the GDPR described above in Section 3 for California residents.
You may assert these rights directly via the Product (to the extent possible) or via the contact options.
Generally, your right to request data access and data portability are described above in Section 3 under the titles "Right to access" and "Right to rectification", respectively. The scopes of these rights differ slightly under the CCPA.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months only. Once we receive and confirm your verifiable consumer request, we will disclose to you:
If we sold or disclosed your personal information for a business purpose, we will disclose such facts separately.
Please note that you may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Generally, your right to request erasure is described above in Section 3 under the name "Right to erasure (Right to be forgotten)".
Despite the fact that the right to request deletion of data under the CCPA and the right to erasure under the GDPR are essentially the same, please note that under the CCPA we are under no obligation to comply with your request if we need to maintain your information for certain reasons. For your convenience, you may find below an abridged version of such exceptions. To learn more, please refer to the full text of the CCPA or the additional clarifications from the California Attorney General.
Under the CCPA, we may retain your personal information if we need it to, among other things:
California consumers have the right to non-discrimination in relation to the exercise of their rights under the CCPA. In particular, we cannot deny you the Product, charge you different prices for the Product, either by denying benefits or imposing penalties, provide you with a different level or quality of the Product in comparison to how we proceed with other California users, or threaten you with any of the above.
Under California's "Shine the Light" law (Civil Code Section § 1798.83) users can request information regarding the disclosure of personal information to third parties for their direct marketing purposes.
We do not sell the personal data we collect (as defined in the CCPA) and will not sell it without providing you with the right to opt out. Please note that we share users' personal information for our business purposes as described in Section 7 "Personal Data Transfers".
Your user journey may vary depending on whether it is the App or the Website (or both) you have chosen to use. Similarly, the scope and peculiarities of data processing will vary:
| Data Category | Website Data Collection | App Data Collection |
|---|---|---|
| General Information | When you start using the Website, or in the course of Website use, we collect the following personal data: Name, Email address, age range, Country of residence, Sex, Other information we may ask you. | When you start using the App, or in the course of App use, we collect the following personal data: Name, Email address, age range, Country of residence, Sex, Other information we may ask you. If you accessed the App from the Website, we may use the information already collected on the Website for the App. |
| Fitness & Wellness Onboarding Information | To tailor your Product experience to your needs, we may ask you to answer some questions about your fitness and wellness experience. Such Fitness & Wellness Onboarding Information may include your height and weight, target weight and body type and target zones, fitness level, sleep information, well-being details. If you do not provide us with Fitness & Wellness Onboarding Information, we will not be able to create a personalized experience for you. | |
| Fitness and Wellness in-App Information | N/A | Data you enter to use the App |
| Customer Support and Other Communications Information | When you contact us for customer support or otherwise communicate with us, you may provide us with information related to your use of the Product, additional contact information, identification documents, or other information you may find helpful to resolve your query. We also collect information on the feedback you provide on the customer support experience. | |
| Your User Choices | We collect: information about your Website settings, privacy settings, and records about when you accepted our Terms of Use, Privacy Notice, and/or provided consent to marketing communications; information on whether you have enabled web browser notifications. | We collect: information about your in-App settings, privacy settings, and records about when you accepted our Terms of Use, Privacy Notice, and/or provided consent to the processing of your data or to marketing communications; information about whether you have enabled push notifications. |
| Feedback Information | We will collect and process your feedback should you communicate it to us. | Our App contains a feature via which you can provide us with feedback, rate our application, and/or engage in deeper discussions. We will collect and analyze the data you submit to make our Product better. We will also collect and process feedback should you communicate it to us in any other way. |
| Data Category | Website Data Collection | App Data Collection |
|---|---|---|
| Usage Information | We collect information about your activity on our Website, like frequency of use, areas and features that you access, visit, or use, and engagement with particular features. | We collect information about your activity on our App, such as: Product interaction, e.g. frequency of use, areas and features that you access, visit, or use, and engagement with particular features. In-App activities, like performed/active workouts, equipment used, gym/home-based workout choices, etc. |
| Device-Related Information | When you install, access, or use the Website, we collect device-related information. This includes IP address, user agent, hardware model, operating system information, browser information, language and time zone, etc. Device-related information also includes approximate location information. | When you install, access, or use the App, we collect device-related information. This includes IP address, user agent, hardware model, operating system information, App version, browser information, mobile network, language and time zone, device identifiers, including Android Advertising Identifier (GAID)/Apple ID for Advertisers (IDFA), etc. Device-related information also includes approximate location information. |
| Log and Troubleshooting Information | We collect some troubleshooting, bug, and crash reporting information from you to help determine problems with the Product. We also collect and write logs to be able to access historical data for internal and external investigations. |
| Data Category | Website Data Collection | App Data Collection |
|---|---|---|
| Advertising Network Information | Advertising networks provide us with insights on which channels (e.g. social networks) and which particular ad campaigns helped you reach the Product. |
On the Website, we also use cookies and other tracking technologies for various purposes. Please refer to Section 6 for more information on cookies and similar technologies.
All processing of your data must be lawful, i.e. reliant upon one of the lawful bases referenced under applicable law, namely:
Below you can see described the purposes of our processing (why we process your information) for each lawful basis and the corresponding data categories used in each case.
As mentioned earlier, your user journey may vary depending on whether it is the App or the Website (or both) you have chosen to use. However, the purposes and legal bases for data processing in relation to the Website and the App coincide.
| Why and how we process your information | Data Used |
|---|---|
| To ensure the intended operation of the Product, namely, to maintain your profile in the Product, ensure you have easy access to it, and provide you with the functionality of the Product provided for in the Product descriptions as well as included materials. For example, we use your data to create plans best suited for you. | General Information, Fitness and Wellness Onboarding Information, Fitness and Wellness In-App Information, Device-Related Information, Usage Information, Your User Choices |
Please note that provision of the information above is necessary for us to provide our Product to you (perform our contract with you). We will not be able to provide the Product without the information listed above. We will also not be able to continue providing the Product if you request data erasure or otherwise restrict our access to such data.
Please note that you can withhold your consent or even revoke it at any time if you change your mind. You can do this either via the App settings or by contacting us. Unfortunately, this will also preclude us from providing you with features relying upon your consent.
| Why and how we process your information | Substantiation of Legitimate Interest | Data used |
|---|---|---|
| To analyze the performance of our Product, improve it, and further deliver a better user experience based on analysis of your interaction with the Product. For example: We count users and events for reporting to identify how many users the Product has. This includes metrics like how many unique users the Product has. We analyze bugs and fix issues with the Product. | Our interest is to measure the use of our Product and count the people who interact with it. Such actions are aimed at improving Product development and enabling the provision of accurate and reliable internal reporting. | Usage Information, Device-Related Information, Log and Troubleshooting Information, Feedback Information |
| To assess the effectiveness of our advertising campaigns by understanding which advertisements led you to the Product and whether you finally used the Product or purchased it/some of its features. | It is our interest to understand who may be interested in our Product and to offer our Product to new potentially interested audiences as well as remind old users about it. | General Information (in a limited scope), Device-Related Information, Advertising Networks Information |
| To communicate with you in various ways, e.g.: to send you technical notices, updates, and security alerts; to send reminders to your smartphone or web browser via in-App messages and in-App and web push notifications; to send promotional communications, such as product updates, offers, discounts, and to provide news and information that we think will be of interest to you. You can opt out of any of our promotional communications anytime as described in your privacy rights section. | We believe the provision of presumably relevant information will be a plus in addition to the provision of the Product functionality. | General Information, Your User Choices, Usage Information, Device-Related Information |
| To provide customer support/ request processing to the customer support team. This includes, for example: responding when you request our help such as assisting with your account login or verification process; addressing your comments and questions. | It is in our interest to assist our users with any inquiries or requests. | Customer Support and Other Communications Information, Usage Information, Device-Related Information, General Information |
| To defend ourselves from prospective legal claims, litigation, or other disputes, including in relation to violations of the Terms of Use, Privacy Notice, and/or other policies. To ensure the safety, security, and integrity of the Product. To provide information to the authorities upon request. | It is in our interest to respond to complaints and prevent and address fraud, unauthorized use of the Product, violations of our Terms of Use and/or other policies, or other harmful or illegal activity. It is in our interest to seek legal advice and protect ourselves (including our rights, personnel, property, or products), and our users or others, including as part of investigations or regulatory inquiries and litigation or other disputes. | General Information, Usage Information, Device-Related Information, Log and Troubleshooting Information |
| To identify disruptions and maintain Product security, including the detection and tracking of inadmissible access attempts and access to our servers. | It is in our interest to eliminate disruptions, maintain system security, and detect and track inadmissible access and access attempts. | General Information, Usage Information, Device-Related Information, Log and Troubleshooting Information |
| Why and how we process your information | Data used |
|---|---|
| Sometimes in order to comply with applicable laws, we need to authenticate you, i.e. collect your identification information. Finally, according to applicable law, we need to understand whether you allow the processing of your data, push notifications, marketing communications, and similar activities. To provide information to authorities upon request. | General Information, Usage Information, Your User Choices |
We do not use your data to make decisions based solely on automated processing that would create legal or comparably significant effects.
A number of Product functions rely upon services from third parties, so-called 'processors'. Processors act based on and in accordance with our requests and shall not use your data for their own purposes.
The main service providers the Product shares your data with are as follows:
We use Amazon Web Services, which is a hosting and backend service provided by Amazon, for personal data hosting and enabling our Product to operate and be distributed to its users.
PostHog helps us understand, in particular, how users find our Product (for example, which advertiser delivered an ad that led you to our Product). PostHog also provides us with different analytics tools that enable us to research, analyze, and make your use of the Product better.
In order to provide you with swift and smooth customer support, we use Front - software that allows us to optimize conversations between users and customer support agents. In this regard, Front receives and stores copies of all data related to your customer support requests, such as emails, purchase details, feedback, etc.
Our customer support team may have access to your information to assist you with inquiries and support requests.
We may share your data with third-party developers and maintenance providers who help us improve and maintain our Product.
We use the services of third-party advertising platforms, for example, Instagram, Facebook, and Snapchat, which allows us to show targeted campaigns and messages to users within their platforms based on the user's behaviour. To put it plainly, we provide information about you that will allow advertising platforms to locate you in their database and information that you performed a desirable action, such as making a purchase.
This allows an advertising network to understand which people are interested in our Product as well as to display advertisements of the Product to users who will most likely want it.
Please note that most advertising networks act as separate controllers or co-controllers of your data in full or in part, which means that such controllers decide whether to use the transferred data for their own purposes, e.g. providing you with advertisements of other providers similar to our Product. We do not share any health & wellness information with advertising networks.
Should you wish to opt out of personalized advertising, please explore the options described in Section 6 above.
We share your information with our affiliates, i.e. companies which are related by having the same owner, for example. Where such sharing takes place, related companies will honor this Privacy Notice.
We may use and disclose personal data to enforce our Terms of Use to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by applicable law.
Please note that in the course of doing business, we transfer your personal data outside of EU/EEA countries. For example, some of our service providers are located in the United States of America.
We shall implement measures as established under applicable law to ensure data transfers are protected as required. When a recipient is located in one of the jurisdictions listed on the official website of the European Commission here, the appropriate safeguard is the corresponding adequacy decision of the Commission. Where no such adequacy decision is present, we rely on the so-called Standard Contractual Clauses (see more about them here), along with a thorough analysis of the law of the destination country to safeguard your data and your rights.
We keep your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless further retention is required under applicable law.
You can request to terminate your account and delete your data at any time. We treat such requests as a termination of your contract with us and as a revocation of your consent(s). We will accommodate such requests and terminate any data processing under respective legal bases.
Please note that certain data can be retained even after your deletion request. That may be the case where processing is based upon our legitimate interest. For example, we may keep information on purchases in order to protect our rights in a legal action. Such storage is not indefinite and is limited to such data's usefulness and achieving our legitimate goals. As described in the Your Privacy Rights and How to Exercise Them section, you may object to our legitimate interests. If you wish to do so, please indicate this specifically in your message to us.
We may also keep data if deletion is not technically possible (for example, because your personal information has been stored in backup archives). We will securely store your personal information and isolate it from any further processing until deletion is possible.
The same applies to cases where we are obliged to retain your data under applicable law (e.g. accounting and tax laws). In the event of such retention, we will ensure via technical and organizational means that such data is not used for conflicting purposes, for example, advertising to you.
By opting in to receive SMS messages from Return, you consent to receive one-time, transactional text messages related to account access and app installation, such as access codes and installation instructions.
Message and data rates may apply depending on your mobile carrier and plan.
You may opt out of SMS messages at any time by replying STOP. For assistance, reply HELP.
SMS consent is not a condition of purchase. No marketing or promotional messages are sent as part of this SMS program.
We process phone numbers solely for the purpose of delivering requested SMS messages, in accordance with this Privacy Policy.
We may change this Privacy Notice from time to time by posting those changes directly on this webpage. Please make sure to review this Privacy Notice regularly. Should the change be major, we will try our best to draw your attention to it, e.g. via a pop-up or email. By continuing to use our Product, you acknowledge you have read and understood the most up-to-date Privacy Notice.