Last updated August 12, 2026

ActinGym Privacy Policy

Effective date: August 12, 2026 Last updated: August 12, 2026

This policy is issued by ActinGym ("ActinGym", "we", "us", "our") and covers the ActinGym iOS app and the website at actingym.com.

1. Scope

This policy describes what we collect, why, who receives it, how long we keep it, whether we sell or share it, and what you can ask us to do. Where a US state privacy law uses the term "business" or "controller", that is us.

2. Notice at Collection

This is our Notice at Collection under California law. Later sections explain these entries rather than adding to them.

Category (statutory term)	What it is for ActinGym	Purposes	Sold or shared?
Identifiers	Account, device and app identifiers, email address, name and display name, profile photo URL, sign-in provider, IP address, analytics identifier, and a pseudonymous purchase token	Account operation, analyses, billing, support, security, analytics, advertising measurement	Yes, Section 8
Customer records information (Cal. Civ. Code §1798.80(e))	Name, email address, subscription status	Account operation, billing, support	Yes, limited to email address and account identifier
Characteristics of protected classifications	An inferred gender attribute about the person on camera, generated automatically. You are never asked for it.	Labelling the analysis record	No
Commercial information	Subscription product and transaction identifiers, purchase and expiry dates, auto-renewal status	Entitlements, billing support, fraud prevention, analytics	Yes
Biometric information (as broadly defined)	Video of your face and recordings of your voice, held as user content. We create no template from them and do not use them to identify you (Section 5).	Producing your analysis	Never, Section 8.2
Internet or other electronic network activity information	In-app events, screens viewed, feature use, crash and error reports, website page views, recorded website sessions, user-agent string	Product analytics, debugging, advertising measurement	Yes
Geolocation data	No precise geolocation. IP address only.	Security, fraud prevention, advertising measurement	IP address: Yes
Audio, electronic, visual and similar information	Your self-tape video; the audio, still images, thumbnail and transcript taken from it; scripts and sides you upload, and their text	Producing your analysis	Never
Professional or employment-related information	Onboarding answers about your acting background, audition frequency, booking level and stage of career	Personalising the product and your training plan	No
Education information	Only if you volunteer it in a free-text onboarding answer	As above	No
Inferences	Craft scores, timestamped notes, prescribed exercises and other conclusions the system draws about your performance	Delivering the product; improving our automated systems	No for performance content. Yes for product-usage inferences such as engagement level or likely plan interest
Sensitive personal information	Sign-in credentials held by Apple or Google on our behalf; onboarding free text that may reveal emotional state; your written self-reflection; any health-adjacent inference a reader could draw from performance notes	Delivering the product; security	Never, Section 9

Retention: every category is kept on the criteria in Section 12. We do not state a period.

Sources: you, in the app; your device; Apple or Google when you sign in; Apple when you subscribe; our analytics and advertising tools; our website.

3. Notes on particular items

Sign-in. You sign in with Apple or Google; there is no password sign-in. The provider's own subject identifier is stored only in hashed form.

Onboarding answers. Some of what you tell us during onboarding is emotionally revealing, so we treat those answers as sensitive personal information (Section 9).

Self-tapes. There is no camera or microphone inside the ActinGym app, and it does not request camera or microphone permission. Every tape you analyse is a video file you already recorded and selected from your photo library.

Scripts and sides. These frequently contain someone else's copyrighted work. We do not sell, license or redistribute them.

Subscriptions. Sold exclusively through Apple In-App Purchase, with Apple as seller of record. We never see, receive or store your card number, bank details or billing address. We store what Apple's verified receipt gives us, and pass Apple a pseudonymous token derived from your account identifier.

Analytics. IP-based location lookup is off, and a filter strips transcripts, script text, media links and email addresses out of event payloads before they are sent. In-app session recording is switched off.

What we do not collect. No camera or microphone access, so the app never records you. No precise geolocation. No payment card data. No faceprint, voiceprint, face-geometry scan or biometric template (Section 5). No date of birth or age field at present (Section 15). We do not buy personal information about you from data brokers and we do not enrich your profile from outside sources.

4. How your analysis is produced

YOUR ANALYSIS IS PRODUCED BY MACHINES, NOT BY A PERSON.

Your scores, your notes and your exercises are generated entirely by automated processing, machine learning and artificial intelligence systems. There is no human review step in producing them: no review queue, no panel of coaches, no manual scoring. Your tape is not routed to a person for assessment, and no one at ActinGym forms a view of your performance.

To produce an analysis, your video, the audio and still images taken from it, your transcript, and any script or sides you upload are sent to Google, an external company, which stores them and processes them by automated means so that results can be returned to us and written to your account. Google is not a reviewer of your work; its systems are part of the automated processing above.

A small number of people at ActinGym can reach stored content when there is an operational reason to, and we would rather say so than pretend otherwise. That means faults and support requests, suspected abuse or unlawful use, security work, and legal process: a person here will look at a tape or link you send us in support, for that purpose only, and a person may access content where we are compelled by valid legal process or reasonably believe it necessary to investigate a credible threat to safety, a serious security incident or suspected unlawful use. That is not part of producing your analysis and it is not a review of your acting. Outside those situations, no one here watches.

These outputs are training feedback. They are not decisions about you. We do not use them, and do not give them to anyone else to use, to decide your access to employment, casting, representation, education, housing, credit, insurance or healthcare.

5. Biometrics: what we do and do not create

This describes how the system works today. It is not a legal conclusion.

ActinGym does not create, derive, store or use a faceprint, a voiceprint, a scan of face geometry, a facial landmark map, a face embedding, a speaker embedding, or any other biometric template. Nothing in our systems detects, locates or measures a face. Separating who spoke within a recording produces no voice signature, template or embedding that we receive or store, and nothing of the kind is compared across recordings, so it cannot be used to recognise you in a different tape. Speakers are matched to lines of the script by comparing words with the transcript, which never touches audio or images. We do not use your face or voice to establish or verify your identity, to authenticate you, or to find you in any other recording, database or image.

The two things we will not gloss over:

Written observations about your face. An analysis can contain a stored English sentence describing visible mouth, lip or jaw movement at a specific moment. It is a human-readable observation, not a measurement and not an identifier, but it is a stored description of your face and you should know it exists.
An inferred gender attribute. The automated system infers and stores a gender attribute about the person on camera. We never ask you for it.

Nothing derived from your face or your voice is sold, leased, traded, licensed or otherwise profited from (Section 8.2).

6. Model training and aggregate data

We may use the content you provide, and your usage data, to develop, train, fine-tune, evaluate, test, benchmark and improve ActinGym's own automated processing, machine learning and artificial intelligence systems, and to build aggregate and statistical products derived from them. We tell you this before you upload, so it is a disclosed purpose at the point of collection and not a later repurposing.

As of the effective date of this policy we do not operate any model training, fine-tuning, dataset-export or evaluation pipeline on user content. The right above is reserved and disclosed, not currently exercised. Where the law requires a separate, unbundled, revocable opt-in before your content may be used that way, we would obtain one through its own in-app consent screen, not through acceptance of our Terms.

We do not use, and do not permit anyone else to use, your voice or your likeness to build, train or offer any capability that generates or simulates a person's voice or likeness.

Google's use of what we send it. Google's own terms govern what Google may do with content submitted through its interfaces. We do not control that, and we make no promise on Google's behalf about whether it uses that content to improve its own products or models. If you do not want your content processed on that basis, do not upload it.

Aggregate data. We may create, use, publish and commercialise genuinely aggregate and statistical information derived from user content, provided it cannot reasonably be used to identify any individual. We do not describe video of a face or a recording of a voice as "anonymised" or "de-identified", because it is not.

7. Who receives your information

Recipient	What they receive	Role
Google	Your videos and thumbnails, the audio and still images taken from them, transcripts, scripts and sides and their text, account records, analysis outputs	Cloud hosting, and the automated processing in Section 4, on our behalf
Apple	Subscription transactions and the purchase token; your sign-in identity if you use Sign in with Apple	Seller of record; identity provider
Our analytics provider	Usage events keyed to your account identifier, crash and error reports, website session recordings	Analytics, on our behalf
Advertising and measurement partners	The signals listed in Section 10	Advertising. Treated as third parties, not processors
Professional advisers, and any acquirer	As reasonably necessary	Legal, accounting, corporate transactions
Law enforcement and courts	As required by valid legal process, or where we reasonably believe it necessary to protect safety, security or legal rights	Compelled or protective disclosure

Every third party with whom we share user data is required, by contract or by the terms under which we use their services, to provide the same or equal protection of that data as is stated in this policy, and as required by applicable law and Apple's App Store requirements.

A current list of the service providers who process user content is available on request at hello@actingym.com.

We sell and share personal information as those terms are defined by California and other US state privacy laws. "Sell" means disclosing it to a third party for money or other valuable consideration. "Share" means disclosing it for cross-context behavioural advertising.

Category sold or shared	Examples	Categories of recipients	Purpose
Identifiers	Email address, account identifier, device and app identifiers, IP address, advertising and analytics identifiers	Advertising networks and advertising-measurement providers; marketing and audience platforms; analytics and marketing-technology providers; buyers of marketing data	Measuring which advertisements led to installs and subscriptions; building and targeting advertising audiences, including audiences resembling our subscribers; and, where we choose to, making marketing contact data available for a recipient's own marketing
Commercial information	Subscription plan, purchase and renewal status, transaction identifiers	Same as above	Advertising measurement, audience segmentation, marketing analytics
Internet or other electronic network activity information	App and website events, pages and screens viewed, user-agent string	Same as above	Advertising measurement, attribution, audience building
Inferences drawn from the above	Engagement level, likelihood of subscribing, plan interest	Same as above	Advertising targeting and marketing analytics

Today the only recipients we treat as third parties for these purposes are our advertising and measurement partners (Section 10). We declare the broader categories because we reserve the right to sell and share them to the other recipients listed, and the law requires notice before we do so, not afterwards.

We have sold or shared the categories above in the preceding twelve months.

Permanently excluded from any sale or sharing, regardless of any consent you might give:

1. Any biometric identifier or biometric information, including any faceprint, voiceprint, face-geometry data, embedding or template. We do not create these, and we do not sell, lease, trade or profit from them anywhere.

2. Script and sides text. This frequently contains someone else's copyrighted work and is not ours to sell.

3. Sensitive personal information (Section 9).

4. The personal information of anyone under 16 (Sections 8.3 and 15).

5. Anything where selling or sharing it would be unlawful where you live, including sensitive personal data of Maryland residents and a minor's personal data where a state prohibits it.

Everything else we hold, including your tape and the material derived from it, may be sold or shared as described in Section 8.1. You can stop that at any time, free and without an account, using Section 14.

8.3 Consumers under 16

We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age, and we do not sell or share the personal information of any consumer we know or reasonably believe to be under 16. ActinGym is offered only to people aged 18 and over. If we learn that a user is under 16, we exclude that user's personal information from all sale and sharing.

9. Sensitive personal information

The sensitive personal information we collect is listed in Section 2. On the broadest reading of the statutory definition it also includes video of your face and recordings of your voice, which we do not process to identify you.

We never sell or share it. We use and disclose it only for purposes permitted without a limitation right: to perform the service you asked for, to secure our systems and detect fraud, to ensure the quality and safety of the service, and to have it processed on our behalf by the recipients in Section 7.

Even though the law does not require it of us on that basis, you may still ask us to limit our use of it using the routes in Section 13. We do not require an account or identity verification for that request, and we act on it within 15 business days.

10. Advertising and website session recording

Advertising. We advertise ActinGym and we measure whether those advertisements work. Through tools in the app and a server-side integration, our advertising and measurement partners receive signals about installs, sign-ups, purchases and similar events. Those transmissions include your IP address and user-agent string, unhashed, and an event identifier that contains your account identifier. We do not send them your video, audio, transcript, script text, self-reflection, scores, notes, or anything derived from your face or your voice. We treat these partners as third parties and these transmissions as a sale and sharing of personal information. On Apple devices your App Tracking Transparency choice also applies, and declining tracking there stops the advertising identifier being shared.

Website session recording. When you visit actingym.com, your session is recorded. Our analytics provider captures the pages you view, where you move and click, how you scroll and how long you stay, and replays it as a recording we can watch, which we use to understand how people move through the site and to fix problems. Two facts matter: the site has no forms and no sign-ups, so there is nothing to type in and no form entries, credentials, payment details or messages to capture; and it covers the website only, because in-app session recording is switched off. The provider processes these recordings on our instructions.

How to stop both. Send a Global Privacy Control signal from your browser and we suppress analytics and session recording for that browser. A browser signal cannot reach an app, so for the app use one of the other routes in Section 14.

11. Where your information is processed, and security

ActinGym is operated from the United States and your information is processed there, on our cloud provider's United States infrastructure. We cannot tell you where Google processes the content we send it for analysis, because the interface we use does not let us declare or control a processing region. If you are outside the United States, using ActinGym means your information is transferred to and processed in the United States, where privacy laws differ from those where you live.

We protect your information with measures appropriate to its nature, including transport encryption, encryption at rest, signed and time-limited upload links, access controls on our storage and database, and hashing of sign-in identifiers. No system is completely secure, and we do not guarantee that your information will never be accessed, disclosed, altered or destroyed. If a breach affecting your personal information occurs, we will notify you and the relevant authorities where the law requires.

12. How long we keep things: criteria, not a countdown

We do not commit to a retention period, and this policy does not promise that anything will be deleted. Content and records may be retained indefinitely.

California law permits a business to disclose either a retention period or the criteria used to determine it. These are ours, and they apply to every category in Section 2. We retain information for as long as one or more of the following is true:

It is needed to provide the service, including so that your library of analyses stays available and your progress can be compared across tapes over time.
It is needed to operate, secure, debug, evaluate or improve the service and our automated systems, including diagnosing why an analysis produced a particular result, which requires the input that produced it.
It is needed to develop, train, evaluate or benchmark our own automated systems, or to produce aggregate and statistical outputs (Section 6).
It is needed for financial, tax, accounting or audit purposes, or to meet a record-keeping obligation.
It is needed to establish, exercise or defend legal claims, to respond to legal process, to investigate suspected fraud, abuse or unlawful use, or to enforce our Terms.
It cannot be isolated and removed at proportionate effort, for example because it sits in backups, system logs, aggregate statistics, or an input already absorbed into a derived output.
It has been pseudonymised or aggregated so that it is no longer associated with an identifiable account, in which case we may retain it without a defined end point.

In practice, everything in an analysis and everything you told us during onboarding is kept for as long as any criterion above applies, which for the core record of an analysis we expect to be indefinitely.

13. Deletion, account closure, and your rights

13.1 What deletion actually does

We would rather tell you what our system does than use a word like "erase" that would not be true.

Deleting a take or a scene removes it from the list shown in the app. The underlying video, the thumbnail and the analysis record are retained. The app cannot delete an analysis record; our storage rules prevent it.

Closing your account is not erasure. Your videos and thumbnails move to a separate retained-storage area no longer presented as part of any account, with no expiry and no automatic clean-up. Your analyses, scenes and scene preparations are pseudonymised, meaning the account identifier and a defined list of personal fields are overwritten, and are kept. Your transcripts, script text, scores and notes, and the words of your self-reflection survive account closure.

We do not describe retained video of a face, or a recording of a voice, as anonymous or de-identified. A face and a voice are identifiers.

13.2 Your rights

Depending on where you live you may have some or all of the following. We extend the process below to all US users, whichever state they are in.

Right to know the categories and specific pieces of personal information we hold about you, the sources, the purposes, and the categories of third parties we disclosed them to.
Right to delete, subject to Section 13.4.
Right to correct inaccurate personal information.
Right to opt out of the sale or sharing of your personal information (Section 14).
Right to limit the use and disclosure of sensitive personal information (Section 9).
Rights relating to automated decision-making technology, including to obtain information about, and opt out of, its use to make significant decisions about you (Section 4).
Right to data portability, where technically feasible.
Right not to be retaliated against for exercising a privacy right. We will not deny you service, charge a different price, or provide a different level of quality, because you did.

13.3 How to exercise them

Email hello@actingym.com, subject line "Privacy Request". This is the primary route and is sufficient for every right above.
In the app, Settings → Privacy, which includes the sale-and-sharing opt-out and account closure.
On the web, actingym.com/do-not-sell/, or a Global Privacy Control signal from your browser.

Verification. For requests to know, delete, correct or port, send the request from the email address on your account and we will match it against our records. If that does not settle it we may ask you to confirm two or three further pieces of information we already hold, or to confirm from inside the signed-in app. We will not ask for a government identity document unless there is no other reasonable way to verify you, and we will not use what you send for anything else. We do not verify identity for opt-out or limit requests.

Authorised agents. You may use one. We may require written, signed permission from you, and may ask you to confirm it directly and verify your own identity. We do not require a power of attorney.

Timelines. We confirm receipt of any request within 10 business days and say how we will process it. We respond to requests to know, delete, correct or port within 45 calendar days, extendable once to 90 days total if we tell you why. We act on opt-out and limit requests within 15 business days, and for an opt-out we notify the third parties we sold or shared to in the preceding 90 days.

Lookback. For a right-to-know request we look back further than 12 months, to 1 January 2022, unless that proves impossible or would take disproportionate effort, in which case we will tell you.

Appeals. If we decline a request and your state gives you an appeal right, reply with the word "Appeal" and we will reconsider and answer in writing with reasons. If we deny the appeal we will tell you how to complain to your state Attorney General or privacy regulator.

Cost. Requests are free, unless one is manifestly unfounded or excessive, in which case we may charge or decline and will explain why.

13.4 Deletion requests and the exceptions we rely on

Where a US state privacy law gives you a deletion right, we comply with a verified request to the extent that law requires. That law also lets a business keep information to complete a transaction, to secure systems and detect fraud, to debug, to comply with a legal obligation, and for internal uses reasonably aligned with your expectations, and it does not require deletion of de-identified or aggregated information. We rely on those exceptions, and we use pseudonymisation and disassociation rather than destruction wherever the law allows. We tell you which exceptions we relied on when we respond.

You have the right to direct us to stop selling and sharing your personal information, at any time, for free, without an account, and without verifying your identity.

14.1 How

A Global Privacy Control signal from your browser. We process it frictionlessly: no charge, no change to the service you receive, no pop-up. A browser sending the signal simply gets no analytics and no session recording. California law lets a business that honours the signal this way do so instead of posting an opt-out link on its home page, and that is the route we have taken.
Our opt-out page, if you would rather send a request directly.
In the app: Settings → Privacy → Do Not Sell or Share My Personal Information.
By email to hello@actingym.com, subject line "Do Not Sell".

We act on the timeline in Section 13.3.

14.2 Opt-out preference signals

We honour opt-out preference signals, including Global Privacy Control (GPC).

A GPC signal sent to actingym.com is treated as a valid request to opt out of sale and sharing for that browser or device and any profile associated with it, including pseudonymous profiles.
If you are signed in when we receive it, we also apply it to your account, so it follows you to other browsers and devices where you are signed in.
The page displays a confirmation that the signal has been processed.
We do not require you to use a signal, and we do not treat the absence of one, at any later time, as permission to start selling or sharing again. Only an affirmative action by you can do that.

14.3 What an opt-out does and does not do

It stops the sale and sharing described in Section 8.1. It does not stop us processing your personal information to deliver the service you asked for, to bill you, to keep the service secure, or to meet legal obligations.

15. Minors

ActinGym is offered only to people aged 18 and over. Our Terms require you to be 18 or older to create an account and to upload a tape. The service is not directed to children and we do not knowingly permit anyone under 18 to use it. Whatever the age of a user in fact:

We do not sell or share the personal information of anyone we know or reasonably believe to be under 16, and we do not have actual knowledge that we do.
We do not use, and do not permit any third party to use, a minor's content for advertising targeting or for model training.
We do not currently ask for a date of birth. If Apple's App Store gives us an age or parental-consent signal, we act on it, do not repurpose it, and do not keep it beyond what that process requires.

If you believe a person under 18 has an account, contact us at hello@actingym.com.

16. Changes to this policy

We may update this policy. When we do, we will change the "Last updated" date and post the new version.

No retroactive repurposing. A materially more permissive use of personal information applies going forward only. We will not apply it to information collected under an earlier version of this policy without your affirmative, express consent for that information.

Material changes get real notice. We will notify you in the app or by email before a material change takes effect, and we will not treat your silence, your continued account existence, or your failure to respond as agreement to a materially more permissive use of your personal information. Where consent is required we will ask for it on its own screen, not by asking you to accept our Terms.

17. Contact us

ActinGym Email: hello@actingym.com

For privacy questions, requests or complaints, email us with the subject line "Privacy". We are the contact point for everything in this policy and for our handling of your personal information.

This policy is linked from the footer of actingym.com and from Settings → Support & Legal → Privacy policy in the ActinGym app.