Last updated: March 12, 2026 | Version 1.0
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.
| Jurisdiction | Authority Notification | Individual Notification |
|---|---|---|
| EU (GDPR) | 72 hours to supervisory authority | Without undue delay if high risk |
| US (FTC Health Breach) | 60 days to FTC | 60 days to affected individuals |
| US (CCPA/CPRA) | As required by state AG | Most expedient time possible |
| UK (DPA 2018) | 72 hours to ICO | Without undue delay if high risk |
| Australia (Privacy Act) | 30 days to OAIC | As soon as practicable |
| Brazil (LGPD) | Reasonable time to ANPD | Reasonable time |
| Canada (PIPEDA) | As soon as feasible to OPC | As soon as feasible |
| India (DPDP Act) | Without delay to DPB | Without 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.
| Level | Description | Response |
|---|---|---|
| Critical | Health data, body images, or financial data exposed to unauthorized parties | Immediate containment, authority + individual notification within 72h |
| High | Personal identity data (name, email) or social data (messages, follows) exposed | Authority notification within 72h, individual notification if high risk |
| Medium | Anonymized or aggregated data exposed, or encrypted data with key intact | Internal investigation, authority notification if risk to individuals |
| Low | System metadata or non-personal operational data exposed | Internal logging and review, no external notification required |
All breach notifications to individuals will include, at minimum:
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).
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.
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.
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.