Your ride data stays on your device.

1. CONTROLLER

The controller for data processing in connection with this app is:

Klaus Neuendorf Thaddäus-Troll-Weg 10 72622 Nürtingen Germany

Email: support@track4facts.com

This policy applies to the Track4Facts PRO app only. A separate privacy policy applies to the website.

German version of this policy: Deutsche Datenschutzerklärung

2. PRINCIPLE: PROCESSING ON YOUR DEVICE

Track4Facts does not operate a server. The app has no user accounts, no registration and no sign-in. Recorded rides, measured values, vehicle data, photos and settings are stored in the app's database on your device.

No data is uploaded automatically to the provider. The provider has no access to your rides, positions, measured values or health data and does not receive them.

Track4Facts itself transmits data only in the following cases, each described separately in this policy:

• when you use a map view or the track assistant (section 4),
• when you export or share a file yourself (section 8),
• when you contact the provider by email (section 10).

Independently of this, data may leave your device through Apple system features that you enable yourself: device backups via iCloud or to a computer may contain locally stored app data, and workouts stored in Apple Health, including heart-rate values, are synchronised with iCloud if you have switched this on in your iCloud settings. These processes are carried out by Apple; the provider has neither access to them nor influence over them. Which data is processed in this context depends on your settings and on Apple's privacy terms.

3. WHAT DATA THE APP PROCESSES

a) Location and ride data

To record a ride and to perform sprint, distance, lap and sector measurements, the app processes position, speed, elevation and time data.

Location recording continues with the screen locked and in the background while a recording is active; iOS indicates this with the system location indicator. The permission can be changed or withdrawn at any time in the iOS settings. Without it, recording and the measurement functions are technically not possible.

b) Motion and orientation sensors

For acceleration, braking and cornering analysis, the app processes the device's acceleration, gravity and rotation rate data through Apple's system interface (Core Motion).

c) Heart rate and Apple Health (optional)

Only if you enable the "Race Training" function and expressly grant access to Apple Health does the Apple Watch start a workout, measure your heart rate during the ride, save the workout to Apple Health and transfer the heart-rate values for the corresponding ride to the paired iPhone. There they are assigned within Track4Facts to the respective ride and to the individual laps.

Permission is granted through the watchOS system dialog and can be withdrawn at any time in the system settings or the Health app, with effect for the future. Without this permission, Track4Facts processes no heart-rate data; all other functions of the app remain fully usable.

Heart-rate data is used solely to display and analyse the heart-rate curve for the respective ride and for the individual laps. The provider does not use it for advertising, marketing, profiling or cross-device tracking, does not disclose it to third parties, and does not sell it.

d) Vehicle data and photos

In the garage you can create vehicles and optionally assign a photo to each. You can take the photo with the camera or select it from your photo library.

Camera permission is requested solely for taking a photo. For selection from the library, the app uses the iOS system picker, which passes only the selected image to the app and grants no access to the rest of your photo library. Vehicle details and selected photos are stored locally.

e) Settings and app state

The app stores your settings locally, together with technical state required for operation — for example the acknowledgement of the safety notice including its version and timestamp. This information remains on the device and is not transmitted to the provider.

4. MAP DISPLAY AND ROUTE MATCHING

For map views, route display and the track assistant, the app uses Apple Maps (MapKit).

When you open a map view or have a recorded route matched against the road layout, the requests technically required for this — including coordinates — are transmitted to Apple and processed there under Apple's terms.

The provider operates no map service of its own for these functions, does not receive these requests and has no access to them. Information on Apple's data processing: https://www.apple.com/legal/privacy/

5. EXTERNAL GPS RECEIVERS AND BLUETOOTH

Supported external Bluetooth GPS receivers can optionally be connected. Bluetooth access serves solely to connect to these devices and to receive the position and speed data they provide. This data is processed locally, like all other ride data.

The hardware, firmware and any services of the respective device manufacturers are outside the provider's control. Where an external receiver or its manufacturer itself processes or transmits data, the respective manufacturer's terms additionally apply.

6. APPLE WATCH, LIVE ACTIVITY AND SPOKEN ANNOUNCEMENTS

The Apple Watch displays values from the running recording and can start and stop it. Data is exchanged directly between the iPhone and the paired watch through Apple's system interface.

The Live Activity displays values from the running recording on the lock screen and in the Dynamic Island of the same device. No data is transmitted to a server for this purpose.

Spoken announcements are generated locally on the device by the iOS speech synthesiser. No speech or text data is transmitted to the provider.

7. NO ANALYTICS, NO TRACKING, NO ADVERTISING

The app contains no analytics, tracking or advertising libraries, no crash-reporting SDK and no third-party services for usage measurement. No advertising identifier (IDFA) is used and no cross-device recognition takes place. There is no profiling and no automated decision-making.

This is to be distinguished from information that Apple makes available to the provider at operating-system and App Store level; that is described in sections 9 and 11.

8. EXPORT, BACKUP AND SHARING

You can export rides as a GPX file, as a CSV file or as a comprehensive backup. An export is always initiated by you; you then decide via the iOS share sheet which app, person or service the file is sent to. The provider does not receive these files.

A separate rule applies to heart-rate data: it is excluded from all exports by default. Only if you enable the separate setting "Heart rate in backup & waypoint CSV" after an explicit warning will future backups and waypoint CSV files contain time-aligned heart-rate values. GPX and motion CSV files never contain heart-rate values.

Disabling the setting later prevents heart-rate data in future exports. Files that have already been exported or shared are not altered by this and can neither be recalled nor deleted at a third party.

Once you transmit a file to a third party, its further processing is governed by the recipient or service you have chosen.

9. IN-APP PURCHASES

The full version is offered as a one-time in-app purchase. Purchase, payment and restoration are handled entirely through the Apple App Store and Apple's StoreKit interfaces.

The provider receives no payment data, no credit card or bank details and no access to your Apple ID. Apple makes sales and transaction information available to the provider through App Store Connect; this does not give the provider the names, addresses or contact details of purchasers. Apple's privacy terms apply to Apple's processing.

10. SUPPORT REQUESTS

If you contact the provider by email, the provider processes the data you send: your email address, the content of your message and any files you choose to attach. This data is used solely to handle your request and any follow-up questions.

Ride, location or health data reaches the provider only if you deliberately attach it to a request. Please send such data only to the extent it is necessary for your enquiry.

The data is deleted as soon as it is no longer required for handling the request and no statutory retention obligations apply.

11. ERROR AND DIAGNOSTIC REPORTS VIA APPLE

If you have consented to sharing with app developers in the iOS settings under "Privacy & Security" → "Analytics & Improvements", Apple may make crash, performance and diagnostic reports available to the provider.

These reports contain technical details about the device model, operating system version, app version and error state. Track4Facts adds no ride, location or health data to them.

The scope and content of these reports are determined by Apple. You can change your consent in the system settings at any time.

12. LEGAL BASES

Where processing of personal data is attributable to the provider under data protection law, it takes place, depending on the operation, on the following bases:

• to provide the app functions you have requested, on the basis of Art. 6(1)(b) GDPR;
• with regard to map display and route matching, on the basis of Art. 6(1)(b) GDPR, as these functions cannot be provided without transmission to the map service;
• with regard to heart rate as health data, on the basis of your explicit consent under Art. 6(1)(a) in conjunction with Art. 9(2)(a) GDPR;
• for support requests connected with a contract or pre-contractual measures, on the basis of Art. 6(1)(b) GDPR, and otherwise on the basis of Art. 6(1)(f) GDPR; the legitimate interest lies in handling enquiries and in error analysis.

Processing of ride, sensor and health data takes place on your device. The provider is not technically involved in this processing and does not learn its contents.

Consent you have given may be withdrawn at any time with effect for the future.

13. RETENTION AND DELETION

Locally stored recordings, vehicle data, photos and settings remain on your device until you delete them. Individual rides can be deleted within the app; deleting the app removes the data held in the app's storage.

Device backups that already exist at Apple or on a computer are not deleted automatically as a result. Their management is governed by your backup settings and the functions Apple provides.

Workouts stored in Apple Health are not deleted along with a ride or with the app. You manage these in the Health app. Whether Health data is synchronised with iCloud depends solely on your own iCloud settings and is outside the app's control.

Section 10 applies to support requests.

14. YOUR RIGHTS

Where personal data is processed, you have the right, within the limits of applicable law, to

• access to the data processed,
• rectification of inaccurate data,
• erasure,
• restriction of processing,
• data portability,
• object to certain processing, and
• withdraw consent you have given, with effect for the future.

Because the provider does not receive your locally stored ride, location, sensor and health data, the provider cannot give information about that data and can neither rectify nor delete it; it resides solely within your control on your device. This does not apply to data you have sent to the provider yourself, for example as part of a support request.

You also have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data infringes data protection law.

15. CHANGES TO THIS PRIVACY POLICY

This privacy policy may be adapted if legal requirements or the functionality of the app change. The version published at the time applies.