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GROW Fitness App – Privacy Policy

Effective Date: May 8, 2025

Thank you for choosing GROW ("GROW", "we", "our", or "us"). Your privacy is important to us. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the GROW iOS and watchOS applications, related services, and any other software or tools we provide (collectively, the "App").

1. Who We Are

Controller: GROW Fitness, sole proprietor (trading as "GROW"), Vienna, Austria

Contact Email: privacy@growfitness.org

We are not required to appoint a Data Protection Officer because, as a micro‑entity, we do not process health data on a large scale. Should this change, we will update this Policy accordingly.

2. Scope of This Policy

This Policy applies to all users of the App worldwide. Because we are established in the European Union, the EU General Data Protection Regulation (GDPR) governs our processing of personal data. Users outside the EU may have additional rights under local laws.

3. Information We Collect

Category Examples Source Legal Basis (GDPR)
Account Information Email address, optional name/username, authentication tokens You Contract (Art. 6 (1)(b))
Health & Fitness Data Exercises, sets, reps, weights, workout history, PRs, templates, plans You / Apple HealthKit (with consent) Explicit consent (Art. 9 (2)(a))
Technical Data Device model, OS version, anonymised usage events, crash logs Automated Legitimate interest (Art. 6 (1)(f))
Purchase Data In‑app purchase receipts (Superwall SDK) Apple Contract / Legitimate interest
Feedback Feature requests, support queries You Legitimate interest

3.1 HealthKit and Apple Watch

Health and fitness data obtained via Apple HealthKit or Apple Watch is processed only after you grant explicit permission and is never used for advertising or shared with data brokers.

4. How We Use Your Information

  1. Provide Core Services – create and track workouts, sync progress across devices, and generate statistics and personalised plans.
  2. Account Management – authenticate you, maintain sessions, and manage in‑app purchases.
  3. Analytics & Improvement – monitor crashes, measure feature adoption, and improve user experience.
  4. Customer Support – respond to inquiries and feedback.
  5. Legal Compliance – comply with tax, accounting, and regulatory obligations.

5. Sharing & Disclosure

We do not sell your personal information. We share data only when necessary:

Category of Recipient Purpose Safeguards
Cloud Hosting & Database Provider (EU‑based) Store and sync workout data, authentication GDPR‑compliant hosting; SCCs where needed
Health Data Sync (Apple HealthKit) Read/write health data (with consent) HealthKit guidelines compliance
Crash & Performance Analytics (EU/US) Crash reporting, performance metrics Data‑processing agreements; pseudonymisation
Professional Service Providers IT support, legal, accounting Confidentiality agreements
Authorities & Courts Respond to lawful requests or protect rights Disclosed only when legally required
Business Transfers In case of a merger, acquisition, or asset sale Notice to users; continued protection

6. International Transfers

Whenever we transfer personal data outside the EU/EEA, we rely on Standard Contractual Clauses or other lawful safeguards under GDPR Art. 46.

7. Data Retention

  • Workout & Health Data: Retained until you delete it or close your account.
  • Account Data: Deleted within 30 days after confirmed account deletion.
  • Local Data: Removed when you uninstall the App.
  • Legal/Tax Records: Retained for the statutory period (typically seven years in Austria).

8. Your Rights

You have the right to:

  • Access and receive a copy of your data
  • Rectify inaccurate data
  • Erase your data (right to be forgotten)
  • Restrict or object to processing
  • Data portability
  • Withdraw consent at any time (without affecting prior processing)
  • Lodge a complaint with the Austrian Data Protection Authority (Datenschutzbehörde, Barichgasse 40‑42, 1030 Vienna, Austria) or your local authority

To exercise any rights, email us at privacy@growfitness.org.

9. Security Measures

We implement technical and organisational measures, including:

  • On‑device encryption (SwiftData, Keychain)
  • TLS encryption in transit
  • Access controls and strong authentication
  • Regular code audits and dependency checks

10. Children's Privacy

The App is not intended for children under 13 (or the minimum legal age in your jurisdiction). We do not knowingly process data from minors. Parents who believe their child has provided data may contact us for deletion.

11. In‑App Purchases & Subscriptions

Premium features are offered via Apple's in‑app purchase system. Payment data is processed by Apple; we receive only anonymised transaction identifiers and entitlement status.

12. Changes to This Policy

We may update this Policy from time to time. Material changes will be announced via in‑app notice or email. The "Effective Date" will always reflect the latest revision.

13. Contact

If you have questions or concerns about this Privacy Policy, contact us at:

GROW Fitness (sole proprietor)
Vienna, Austria
Email: privacy@growfitness.org

Thank you for trusting GROW with your fitness journey.

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