Data Breach Notification Policy

Last updated: March 12, 2026 | Version 1.0

1Purpose and Scope

This policy establishes the procedures FitJourney follows in the event of a personal data breach, as required by GDPR Article 33, the FTC Health Breach Notification Rule (16 CFR Part 318), CCPA/CPRA, UK Data Protection Act 2018, Australia Privacy Act 1988, Brazil LGPD, and other applicable data protection laws. A "personal data breach" means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

Given that FitJourney processes health data (body measurements, dietary information, fitness activity) classified as special category data under GDPR Article 9, any breach involving this data is treated with the highest severity level.

2. Notification Timelines

JurisdictionAuthority NotificationIndividual Notification
EU (GDPR)72 hours to supervisory authorityWithout undue delay if high risk
US (FTC Health Breach)60 days to FTC60 days to affected individuals
US (CCPA/CPRA)As required by state AGMost expedient time possible
UK (DPA 2018)72 hours to ICOWithout undue delay if high risk
Australia (Privacy Act)30 days to OAICAs soon as practicable
Brazil (LGPD)Reasonable time to ANPDReasonable time
Canada (PIPEDA)As soon as feasible to OPCAs soon as feasible
India (DPDP Act)Without delay to DPBWithout delay

FitJourney commits to notifying the relevant supervisory authority within 72 hours of becoming aware of a breach (the strictest common standard), and affected individuals without undue delay when the breach is likely to result in a high risk to their rights and freedoms.

3Incident Response Procedure

Phase 1: Detection and Containment (0-4 hours)

  • Identify the nature and scope of the breach
  • Contain the breach to prevent further data loss
  • Preserve evidence for forensic investigation
  • Activate the incident response team
  • Document initial findings in the breach register

Phase 2: Assessment and Risk Evaluation (4-24 hours)

  • Determine the categories and volume of data affected
  • Assess the risk level (low, medium, high, critical)
  • Identify affected data subjects and their jurisdictions
  • Evaluate whether health/special category data is involved
  • Determine notification obligations per jurisdiction

Phase 3: Notification (24-72 hours)

  • Notify relevant supervisory authorities with required details
  • Prepare individual notification communications
  • Notify affected individuals via email and in-app notification
  • If 500+ individuals affected (US): notify prominent media outlets
  • Notify sub-processors if their systems were involved

Phase 4: Remediation and Review (72+ hours)

  • Implement corrective measures to prevent recurrence
  • Conduct post-incident review and lessons learned
  • Update security measures and policies as needed
  • Provide follow-up communications to affected individuals
  • Update the breach register with final assessment

4. Breach Severity Classification

LevelDescriptionResponse
CriticalHealth data, body images, or financial data exposed to unauthorized partiesImmediate containment, authority + individual notification within 72h
HighPersonal identity data (name, email) or social data (messages, follows) exposedAuthority notification within 72h, individual notification if high risk
MediumAnonymized or aggregated data exposed, or encrypted data with key intactInternal investigation, authority notification if risk to individuals
LowSystem metadata or non-personal operational data exposedInternal logging and review, no external notification required

5. Notification Content

All breach notifications to individuals will include, at minimum:

  • A description of the nature of the breach in clear, plain language
  • The name and contact details of our data protection contact
  • A description of the likely consequences of the breach
  • A description of the measures taken or proposed to address the breach
  • Specific categories of personal data affected (especially if health data)
  • Recommendations for individuals to protect themselves
  • Information about the right to lodge a complaint with a supervisory authority

6Breach Register

FitJourney maintains an internal breach register documenting all security incidents, regardless of whether they trigger notification obligations. The register records the facts of the breach, its effects, and the remedial action taken. This register is available to supervisory authorities upon request, as required by GDPR Article 33(5).

7Sub-Processor Breach Obligations

Our sub-processors (Stripe, AWS S3, TiDB Cloud, Umami Analytics) are contractually obligated to notify FitJourney of any data breach without undue delay. Upon receiving such notification, FitJourney will assess the breach and fulfill its own notification obligations as described above. See our Data Processing Agreement for details on sub-processor obligations.

8. Security Contact

To report a security vulnerability or data breach, contact us at:

We operate a responsible disclosure policy. Security researchers who report vulnerabilities in good faith will not face legal action. We aim to acknowledge all security reports within 24 hours and provide an initial assessment within 72 hours.

9Policy Review

This breach notification policy is reviewed annually and updated whenever there are material changes to our data processing activities, applicable laws, or organizational structure. All staff with access to personal data receive training on breach identification and reporting procedures.

This document forms part of FitJourney's data protection framework alongside our Privacy Policy, Terms of Service, and Data Processing Agreement.