Effective Date: January 1, 2026

This Privacy Policy describes how Groupe MonGym Inc., a corporation incorporated under the laws of Québec and operating the mobile application under the name Reppa (“Reppa”, “we”, “our”, or “us”), collects, uses, retains, shares, and protects your personal information when you use the Reppa mobile application (the “Services”).

When you first use the application, an explicit consent mechanism is presented to you.

By using Reppa, you consent to the collection and use of your information in accordance with this Policy.

You may withdraw your consent by deleting your account.

1. Scope

This Policy applies to the Reppa platform, including mobile applications, products, websites, technologies, software, and related services (collectively, the “Services”). Please also read our Conditions of Service (the “Terms”), which set out the terms governing our Services. For the purposes of this Policy, Reppa acts as the data controller or “business” with respect to the personal information we process. This means that we determine how and why the personal information we collect is processed.

2. Information Collected by Reppa

We collect only the information necessary for the operation and improvement of the Services.

Identification Information

• Full name

• Email address

• Profile photo (optional)

Demographic Information

• Date of birth (age verification)

• Gender

• Preferred language

Technical Data

• Diagnostic data and crash reports (crash logs)

Usage Data

We use certain technologies (such as internal identifiers or analytics tools) to understand how the application is used, measure performance, and improve the user experience.

Information From Use of the Services

Content you share: we collect the content you share through the Services, such as your photos, videos, posts, comments, and messages.

Activity Data: we collect your Activity Data, either directly or through third-party integrations that you configure. “Activity Data” refers to information relating to your activities that you record or upload to Reppa, such as equipment used, date, duration, exercises, weights, training metrics, and geolocation information.

Information about your usage: we collect information about how you use the Services, such as your involvement in a club or your participation in challenges, kudos, your participation in partner events, and the actions you perform, such as viewing or interacting with other users’ activities.

Information about your device: we collect technical information from the browser, computer, or mobile device you use to access the Services. This includes information about the device itself and the network, log files, and analytics information.

Cookies, analytics, and third-party technologies: we collect and use certain information through cookies and similar technologies. Please see the section Cookies and Similar Tracking Technologies below.

Information From Other Sources

Third-party accounts: you may register and log in to the Services using accounts from other companies, such as Google or Apple (“Third-Party Accounts”). If you access the Services through Third-Party Accounts, we will collect certain information such as your name, email address, profile, and preferences. To control the information we receive from Third-Party Accounts, you must use the privacy settings of those accounts.

Service providers: we may collect certain information through our service providers, for example your responses in connection with surveys.

Other users: we may collect information about you from other Reppa users, for example when they congratulate you or comment on your activities.

3. How Reppa Uses Information

To Provide the Services

Creating and updating your Account: we process certain information, such as your Account and Profile information, to create and update your account.

Recording your activities and analyzing your performance: we process your Activity Data and other information to help you record and analyze your performance. For example, we may compare your past efforts or help you set training goals. We may also link your geolocation to certain workouts in order to compare your efforts with those of other users and establish rankings.

Personalizing your experience: we use certain information to personalize your experience. For example, we may suggest challenges, clubs on Reppa, users to follow, or new features.

Providing AI Features: we use and develop machine learning (“ML”) and artificial intelligence (including large language models) (“AI”) to provide you with features designed to enhance your training and our Services (“AI Features”). AI Features include, for example, protecting the integrity and security of our Services (such as detecting anomalies in leaderboards), generating route recommendations, or providing personalized training advice. Depending on your privacy settings and sharing permissions, we may also use personal information such as health and geolocation information for the benefit of AI Features, for example to provide you with training analyses and recommendations.

Visualizing your activities: we use certain information for the visual presentation of your activities, for example by creating visualizations based on your training log or performance metrics.

Notification Emails and Operational Communications: We use your email address to send you communications that are necessary for the proper functioning of the service. These communications are strictly operational and informational in nature and may include, without limitation, notifications related to account activity, security, important service updates, functional changes, or any other essential information required to provide an optimal user experience and a high-quality service. These communications are an integral part of the use of the Reppa service and may be sent for as long as the user maintains an active account.

Contacting you about the Services: we may contact you about material changes to our Terms, when we investigate suspected violations, or through customer support messages.

To Assist You With a Request

We use certain information to respond to your requests and feedback. Depending on your request, we may need to access your account (for example, to resolve or reproduce a reported issue).

To Analyze and Improve Our Services

Analytics: we use certain information to measure traffic and usage trends of our Services, to understand how visitors interact with our content, and to make improvements. This may involve the use of cookies and other tracking technologies, as described in the section Cookies and Similar Tracking Technologies.

Improving the Services: we use certain information to conduct research and to analyze, develop, troubleshoot potential issues, and improve the functionality of our tools and Services.

Developing AI Features: we use certain information to improve the quality, reliability, and/or accuracy of our AI Features by creating, developing, training, testing, improving, and maintaining AI and ML models operated by Reppa or our service providers. Where possible, we use certain aggregated and de-identified information for our AI Features.

To Provide You With Sponsored Content and Marketing and Advertising Communications

Sponsored content: we use certain information to present challenges, segments, and other content sponsored by third parties such as brands or event partners.

Marketing and promotions: we use certain information to send you content related to our Services and to suggest or offer promotions, trial offers, specific features, or activities.

Targeted advertising: we advertise our Services through third parties and may use cookies and other tracking technologies to support targeted advertising and deliver relevant ads.

To Protect You, Others, and Our Services

We seek to protect users, enforce our Terms of Service, and promote safety. For these purposes, we use certain automated tools, device data, log files, and other information. For example, we work to detect abuse and malicious actors, and to remove content that violates our Terms, such as hate speech or spam. We reserve the right to review user accounts and activities to ensure compliance with our Terms, and we may suspend or terminate accounts accordingly. We may also process certain of your information when we believe it is necessary to prevent serious harm.

To improve safety and protect the privacy of our younger users, we use your age to confirm that you are old enough to use Reppa and to provide an age-appropriate experience, including through our messaging.

To Conduct Research in the Public Interest

We may process certain information as part of research aimed at improving public safety, health, or well-being.

To Manage Legal and Regulatory Obligations

We may use certain information to manage or respond to legal requests or obligations from governmental authorities or other regulatory bodies in connection with our Services.

4. How Reppa Shares Your Information

We may share your information as follows:

Information Visible to Others

Some of your information may be visible to other Reppa users and to the public. If you are 18 or older, certain information, including your profile and your activities, is set by default to be visible to “Everyone.” By “Everyone,” we mean Reppa users and the public, including through search engine results.

Subject to your privacy settings, your information may be viewed on Reppa or by non-registered users, including certain sections of your profile, your name, your photos/videos, the information and content you share (including your geolocation, such as the gym where you train), the users you follow and who follow you, the clubs you belong to on Reppa, your Activity Data, the devices you use, your online status, as well as the kudos and comments you give and receive.

Service Providers

We may share your information with third parties to support, improve, promote, and secure our Services, process payments, or fulfill orders. These service providers have access only to the information necessary to perform specific functions on our behalf. We require them to protect and secure your information.

Third-Party Services

You may choose to share your information and content with third-party applications, plugins, or websites that integrate with our Services, as well as with third parties that work with Reppa to offer integrated features, such as sponsoring a challenge, distributing media, or providing a tracking device. The information you provide to these third parties is subject to their own terms and policies.

When you choose to use a Third-Party Account to sign in to Reppa, we share only the information necessary for login and security. You may also share your information (including your Activity Data) via SMS, email, or on social media applications such as Instagram. Activities you share with other social networks may be visible on those platforms and may include your geolocation information.

Partners

We may disclose information to certain partners, such as those who sponsor or organize events or manage clubs you join, when you consent to or request such sharing. We may also disclose information to marketing partners or third-party advertising networks in order to promote our Services (with your consent, where applicable). We may also disclose certain information through the use of cookies and similar technologies, as explained in the section Cookies and Similar Tracking Technologies below.

We do not share with any third party data relating to SMS message acceptance and consent.

Affiliates, Subsidiaries, and Acquirers of Our Business or Assets

We may share your personal information with our family of companies, including our affiliates and subsidiaries. Our subsidiaries may process this information in accordance with their own Privacy Policies. Please see this link for more information about our subsidiaries.

If Reppa is involved in a merger, acquisition, securities offering, bankruptcy, reorganization, dissolution, or any similar transaction, we may, as part of that transaction, share or transfer certain of your information.

Legal Requirements and Harm Prevention

We may retain and share your information with third parties, including law enforcement authorities, public or governmental agencies, or private parties, within or outside your country of residence, if we determine that applicable law requires or reasonably demands such disclosure. This may include responding to court orders, warrants, subpoenas, or other legal or regulatory processes, or otherwise disclosing information as permitted by law.

We may also retain, preserve, or disclose your information if we determine that it is reasonably necessary or appropriate to do so in order to: (1) prevent loss of life, serious bodily injury, or other significant harm; (2) address national security matters or other issues of public importance; (3) prevent or detect violations of our Terms or fraud or abuse against Reppa or its users; or (4) protect our operations, property, or other legal rights, including in connection with actual or potential litigation.

5. Cookies and Similar Tracking Technologies

We collect, use, and disclose information through cookies, tracking pixels, SDKs, Google Analytics, and other third-party tracking technologies for security and authentication purposes, to understand and improve your experience, to perform analytics, to inform and deliver relevant advertising, to understand how you interact with advertisements, and to enable you to browse and use our Services.

6. Your Privacy Rights and Choices

We offer a range of privacy settings to manage your information. We encourage our users to adjust these controls based on the experience they wish to have.

Below are the privacy rights you may have under applicable laws, depending on your place of residence and subject to any limitations or exceptions. If you need assistance exercising your rights, please use the contact information in the Contact Us section to reach us.

Access and portability: you have the right to know what personal information we collect, use, share, or otherwise process about you, and to request access to it. You can access most of your information by logging into your account.

Rectification or correction: you have the right to correct inaccurate information. You can correct, modify, or update your Profile or Account information at any time through your account settings.

Restriction or deletion: you have the right to delete or restrict access to certain personal information. This can largely be done through your account, for example by deleting content such as photos or videos you have posted, deleting individual activities or their summaries, or deleting your account. Once your data is deleted, including your account, your activities, and your position on leaderboards, we cannot restore them. Deletion of your personal information and system logs may take up to 45 days following account deletion.

We have no control over content you may have shared directly or publicly with others, such as photos or videos on other social media platforms, or that others may have copied. Search engine results may also continue to display your public profile until the search engine refreshes its cache.

Withdrawal of consent: to the extent that we rely on your consent to carry out certain processing activities, you have the right to withdraw that consent at any time. This can be done through your settings. Please note that withdrawing your consent does not affect prior processing carried out on the basis of that consent. For example, past activities will continue to display information (such as heart rate data) for which your consent had previously been given.

Automated decision-making: we sometimes use AI Features and automated decision-making to analyze your personal information, as described above. However, we do not use these technologies to make decisions that have legal effects or other similarly significant effects on you.

7. Children’s Privacy

Our Services are not intended for children under the age of 13, and we do not knowingly collect personal information from this audience. If you are under 13 years of age, please do not use our Services.

8. Other Important Privacy Information

How Reppa Protects Information

We implement measures to manage your information securely and in accordance with this Policy. We maintain administrative, technical, and physical safeguards consistent with relevant industry standards, designed to protect personal information against unauthorized use, disclosure, or access.

Retention of Information

We retain information for as long as necessary to provide our Services, subject to our legal obligations. We generally retain information associated with your account until you delete it or until we no longer need it to provide our Services. Before making such determinations, we assess the volume, nature, and sensitivity of the personal information, the purposes of the processing, applicable legal obligations, and whether our objectives can be achieved through other means.

9. Updates to the Privacy Policy

Reppa reserves the right to modify this Policy at any time. In the event of changes to this Policy, we will post the revised version and its effective date on our website. In the case of material changes, you will receive more formal advance notice. If you do not agree with any change to this Policy, you must stop using our Services and delete your account.

10. Contact Us

If you have any questions about our personal information practices, this Policy, or if you wish to contact us, you may do so by email at the following address: support@reppaapp.com