Masculine Frame Privacy Policy

Controller: Bear in Studio Ltd (company number 14642085)
Registered office: 39 Goldhawk Road, London, W12 8QQ, United Kingdom
Contact: hello@bearinstudio.com

1. Who we are

Masculine Frame is a coaching programme operated by Bear in Studio Ltd, a company registered in England and Wales. Bear in Studio Ltd is the data controller for the personal data described here.

Registration with the Information Commissioner's Office (ICO) is being completed. The registration number will be published here once it is issued.

Masculine Frame is a coaching and education programme. It is not a medical device, and it does not diagnose, treat, cure or prevent any disease or medical condition. Nothing in the Access Hub or in BSIS is medical advice; consult a qualified professional before acting on health concerns.

2. What this policy covers

This policy covers two connected systems:

(a) the Masculine Frame Access Hub at app.masculineframe.com, where your coaching happens: your programme, your training log, your check-ins, your messages with your coach and your billing record; and
(b) Bear Intelligence (BSIS), a separate AI-assisted system used for guided onboarding, daily nutrition, sleep and bodyweight logging, and weekly Check-In preparation. Its wider conversational, memory and reflection features are optional.

The two are deliberately separate. Neither reads the other's data. Where information moves between them, you move it, by copying and pasting it yourself. The one exception is described in Section 9.

This policy should also be read alongside the Masculine Frame Programme Terms, which set out the coaching service itself, and the BSIS End User Agreement, which governs your use of that application.

3. What we collect, and why

Account and contact details. Your name, email address, phone number and date of birth, provided when you apply and register. Used to give you an account, identify you to your coach, and contact you about your membership. Your date of birth also confirms you meet the minimum age of 18 required to enrol (Programme Terms, Section 3.1).

Health and fitness information. What you tell us about your body, goals, training history, injuries and relevant health factors, during onboarding and throughout coaching. Used to write and adjust your programme safely. This is special category data under UK GDPR; see Section 4.

Training records. Every workout you log: exercises, weights, repetitions, times, the gym you trained at, and personal records calculated from them. Used to run the programme and show you your own progress.

Check-ins and progress media. Your weekly written check-ins, the progress photographs you upload, and any videos you record for form review. Used by your coach to review your progress and answer you.

Messages. Your conversation with your coach inside the Access Hub, including any files and voice notes.

Membership and billing records. Your subscription status, billing dates and payment confirmations. We never see or store your full card number.

Device health measurements. Only if you connect your phone or watch, and only from that point on: your daily step count, sleep, exercise minutes and resting heart rate, as measured by your own device. Used so that your coach can see how you are actually recovering and moving between sessions without you having to report it. This is health data and therefore special category data; see Section 4. It is off unless you turn it on, you can turn it off at any time, and when you do we stop receiving new measurements. We receive only the figures listed here - we do not receive your location, your device's raw sensor data, or anything else your device holds.

Technical data. Your device time zone, so that every date in the Access Hub matches your own day; the session cookie that keeps you signed in; and, if you turn notifications on, a push subscription for the device you enabled them on. See Section 12.

Bear Intelligence content. If you use BSIS: your conversations with it, the daily nutrition, training and sleep notes you log there, and the targets and decisions you record.

What we do not collect. Payment card numbers, CVV codes or bank credentials (these go directly to Stripe); your device's location, contacts, camera roll or microphone beyond a photo or video you deliberately choose to upload; and data bought or acquired from data brokers.

4. Our legal bases

Contract. Most processing is necessary to deliver the coaching you have paid for: your account, your programme, your training records, your check-ins and your messages.

Explicit consent (Article 9(2)(a) UK GDPR). Health and fitness information is special category data. We process it on the basis of your explicit consent, collected at onboarding as a separate step from accepting the Programme Terms. You may withdraw that consent at any time, though we cannot continue coaching you safely without it.

Explicit consent, separately, for device health measurements. These are special category data too, and they rest on their own consent: connecting your phone or watch is a deliberate act you take in the Access Hub, it is off until you take it, and it is not part of accepting the Programme Terms or of the onboarding consent above. Withdrawing it stops collection and does not affect your coaching - unlike the consent above, this one is not necessary to coach you safely.

Legal obligation. Financial and accounting records are kept because UK company and tax law requires it.

Legitimate interests. Keeping our systems secure, preventing abuse, keeping a record that a deletion request was honoured, and (for the session cookie in Section 12) letting you stay signed in at all.

5. Where your data is stored

The Access Hub, its database, and everything you upload to it, including check-in photographs and videos, are hosted on a server operated by Bear in Studio Ltd on infrastructure provided by DigitalOcean, LLC, physically located in Amsterdam, the Netherlands. BSIS runs on the same infrastructure. Nothing you upload is sent to a separate image service, a content delivery network, or any object storage provider outside that infrastructure.

6. Who processes your data

We do not sell your personal data to anyone, and we do not use it for advertising or cross-app tracking.

DigitalOcean, LLC hosts both the Access Hub and BSIS on a server in Amsterdam, the Netherlands, inside the European Union. DigitalOcean provides technical hosting only and does not otherwise access your data. DigitalOcean is incorporated in the United States; see Section 7 for the safeguard this relies on.

Stripe processes subscription payments under its own PCI-DSS compliant systems. Your card details go directly from your browser to Stripe; they do not pass through, and are not stored on, our systems. Entity: Stripe Payments Europe, Limited (Ireland), with Stripe, Inc. (United States) as its affiliate.

Supabase provides the sign-in layer: it holds your email address and credentials, and issues the session cookie described in Section 12. Your coaching data is not stored there.

Resend delivers transactional email, such as an application decision or a confirmation that your account has been deleted. It receives your email address and that message only. Entity: Resend, Inc. (United States). We do not use it to send marketing email, and your address is not added to any mailing list.

Google operates the large language model that answers you inside BSIS. Anything you type into BSIS is sent to that model in order to generate a reply, including anything you choose to tell it about your health, training, nutrition or sleep. If you would rather something did not reach a third-party AI provider, do not type it into BSIS. BSIS is required for guided onboarding, daily nutrition, sleep and bodyweight logging, and weekly Check-In preparation. Its wider conversation, memory and reflection functions are optional. Anything entered into BSIS, including required workflow information and any additional information the member chooses to add, is sent to Google’s model to generate a response.

Professional advisers. Our accountant and, where necessary, our legal advisers may see billing and contractual records in the course of advising us. They are bound by professional confidentiality obligations.

Legal disclosures. We may disclose data where we are legally required to: a court order, a valid request from a regulator or law enforcement, or where disclosure is necessary to establish, exercise or defend a legal claim. Where we are permitted to tell you, we will.

7. International data transfers

Your coaching data is stored inside the European Economic Area, in Amsterdam. Three of our processors are United States companies, or have a United States affiliate:

• DigitalOcean, LLC. The infrastructure your data sits on is in the EEA. Where DigitalOcean personnel in the United States could access it for support purposes, the transfer is covered by the Standard Contractual Clauses in DigitalOcean's Data Processing Agreement, together with the UK International Data Transfer Addendum.
• Stripe. Transfers to Stripe, Inc. in the United States are covered by Standard Contractual Clauses and the UK Addendum, together with Stripe's own transfer mechanisms.
• Resend, Inc. Service emails are delivered through infrastructure operated from the United States, covered by Standard Contractual Clauses with the UK Addendum under Resend's data processing agreement.
• Supabase. Sign-in is handled by a United States company under its own data processing agreement, covered by the same Standard Contractual Clauses and UK Addendum mechanism.
• Google. BSIS conversations reach a US-headquartered provider; see the BSIS End User Agreement for the transfer mechanism that governs that specific flow.

Where any transfer outside the UK takes place, it is made under an approved safeguard: the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or a valid adequacy decision. You can request a copy of the relevant safeguards by emailing hello@bearinstudio.com.

8. How long we keep it

While you are a member, and for 12 months after your membership ends, we keep your coaching and membership data, so that any later question or dispute can be answered.

If you delete your account, we delete that data within 14 days. See Section 10.

Financial and accounting records are kept for at least 6 years, because UK company and tax law requires it. These are billing entries only: no training data, no photographs, no messages.

Device health measurements follow the same rule as your coaching data: kept while you are a member and for 12 months afterwards, and deleted within 14 days if you delete your account. Turning the connection off stops new measurements arriving; it does not by itself erase the ones already recorded, which is what the deletion route is for.

BSIS conversation data is kept for 6 months after your membership ends, unless you delete your account or ask for it sooner.

9. Where information crosses between systems

The Access Hub and BSIS do not exchange data automatically. There is a single, one-directional exception: your coach can record a durable note about you, such as a stated injury or a training preference, into your BSIS memory so that BSIS answers you with that in mind.

Two things follow from this, and we would rather state them plainly than bury them:

(a) the note travels into BSIS only. Nothing ever travels back out of BSIS to your coach. What you tell BSIS stays in BSIS unless you copy it out yourself;
(b) a copy of that note also stays in the coaching team's own internal memory-management system. That copy holds only notes a coach entered. It never holds your conversations, your daily logs or your messages. It survives deletion of your BSIS account, and is covered in Section 10.

Your own device is a separate matter. If you connect your phone or watch, measurements travel from your device into the Access Hub. That is a different flow from the one above: it starts on hardware you own, it goes into the Access Hub and not into BSIS, and it happens only because you switched it on. Nothing measured by your device is sent to BSIS, and nothing in BSIS is sent to your device.

10. Deleting your account

You can delete your account yourself, at any time, from My Profile in the Access Hub. You do not need to email anyone or wait for approval.

Deleting your account cancels your membership immediately, closes your access, and within 14 days permanently removes:

(a) your profile, sign-in details and profile photo;
(b) every workout you have logged, and all of your records;
(c) every check-in, including progress photographs and videos;
(d) your whole message history with your coach, including voice notes;
(e) your BSIS account, including its conversations, daily logs, targets, decisions and stored memories.

What is kept, and why. Only three things:

(a) billing records, for at least 6 years, because UK company and tax law requires it. Article 17(3)(b) UK GDPR permits retention necessary for compliance with a legal obligation;
(b) coach-entered memory notes, in the internal system described in Section 9. These are retained under Article 17(3)(e) UK GDPR, which permits retention necessary for the establishment, exercise or defence of legal claims, so that the guidance recorded about you can be evidenced. You may ask us to erase these and we will, unless they are still needed for that purpose;
(c) a dated record that a deletion was requested and completed, as proof the request was honoured.

Once the 14 days have passed, deletion cannot be reversed. Within that window, email hello@bearinstudio.com.

At launch, coaching is provided by Gokhan Can; where Bear in Studio Ltd appoints an additional Masculine Frame coach, you are told before responsibility for your coaching is transferred.

11. Your rights

Under UK GDPR you have the following rights. Exercising any of them is free, and we will respond within one calendar month.

Right of access (Article 15). Ask for a copy of the personal data we hold about you.

Right to rectification (Article 16). Ask us to correct anything inaccurate.

Right to erasure (Article 17). Ask us to delete your data. See Section 10, which goes further than the law requires.

Right to restriction (Article 18). Ask us to pause processing while a dispute is resolved.

Right to data portability (Article 20). Ask for your data in a structured, machine-readable format, or ask us to send it directly to another provider where that is technically feasible.

Right to object (Article 21). Object to processing based on legitimate interests. We will stop unless we can show compelling legitimate grounds that override your rights.

Right to withdraw consent (Article 7(3)). Withdraw consent for health data processing at any time. See Section 4.

Rights relating to automated decision-making (Article 22). See Section 13. We do not make automated decisions with legal or similarly significant effects about you.

To exercise any of these, email hello@bearinstudio.com. We may ask you to confirm your identity before we act, which protects you rather than us. You do not need to give a reason, and exercising a right will never affect the standard of your coaching.

If you believe we have handled your data wrongly, tell us first at hello@bearinstudio.com so we can put it right. You also have the right to complain to the supervisory authority at any time, and you do not have to come to us first: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Helpline 0303 123 1113, www.ico.org.uk.

12. Cookies and device storage

The Access Hub uses one session cookie, issued by Supabase, to keep you signed in. This is strictly necessary for an application with a sign-in to function, and it is exempt from consent requirements under the Privacy and Electronic Communications Regulations on that basis. We set no advertising cookies, no cross-site tracking cookies, and no third-party analytics cookies.

The Access Hub also uses your browser's own local storage for a small number of strictly functional purposes: keeping a workout or a message you are writing safe if your connection drops, so you do not lose it; queuing something you sent while offline until it can reach us; remembering your device's local time zone; and remembering whether you have already seen a one-time onboarding tour, so it does not replay. None of this is used to track you, none of it is shared with anyone, and none of it leaves your device except the specific content you are actively saving (a workout, a message) once your connection allows it.

The masculineframe.com marketing website sets no cookies. It stores a small amount of information in your own browser to remember which page and campaign link you arrived from, described in full on that website's own privacy page. That information stays on your device and is never transmitted to us except as parameters on the link you follow if you begin an application.

If this changes, this policy will change first, and anything requiring consent will ask for it before it runs.

13. Automated decision-making and profiling

No decision about your coaching is made automatically. Your phase, your programme, your nutrition direction and every change to any of them are decided by a person who has read your record. Your application is read by a person; it is not scored by an algorithm.

BSIS generates automated responses to what you write in it. Those are software outputs, not decisions about you, and they have no legal or similarly significant effect. They do not change your programme; only your coach does that.

Nothing about you is used to train any AI model.

14. Security

Your data is held on a server in the European Union, transmitted over encrypted connections, and reachable only through your own signed-in account. Passwords are stored hashed, never in readable form. Access to the production server is restricted to key-based authentication. Your coach can see the members assigned to them; administrators can see the accounts they manage. We keep the number of people with access deliberately small. Progress photographs and videos are served only to you and your coach, never publicly.

No system is perfectly secure and we will not claim otherwise. Where a breach occurs that is likely to result in a risk to your rights and freedoms, we will report it to the ICO within 72 hours of becoming aware of it, and tell you directly where the risk to you is high.

15. Children

Masculine Frame is for adults. We do not knowingly provide the service to anyone under 18, and we do not knowingly collect their data. If you believe a child has given us personal data, email hello@bearinstudio.com and we will delete it.

16. Changes to this policy

If we change this policy we will update the version and effective date at the top. Where a change materially affects how we use your data, we will tell you in the Access Hub rather than relying on you to re-read this page.

17. Related documents

• Masculine Frame Programme Terms govern the coaching service itself: what is included, what is not, payment, cancellation and the limits of the service.
• BSIS End User Agreement governs your use of Bear Intelligence, including its own privacy terms for what you put into that application specifically. You accept it inside BSIS at first sign-in.

Where this policy and the BSIS End User Agreement both touch the same question, this policy governs your Masculine Frame coaching data and that agreement governs your BSIS account contents.

18. Contact

Bear in Studio Ltd
39 Goldhawk Road, London, W12 8QQ, United Kingdom
Company number 14642085
hello@bearinstudio.com