Privacy Policy for Pacing App

Last Updated: 31st March 2025

1. Introduction

Welcome to Pacing (“the App”), provided by Practicable LTD (“we,” “us,” or “our”). Practicable LTD is a company based in the European Union and is committed to protecting your privacy in compliance with the General Data Protection Regulation (GDPR) and other relevant data protection laws.

This Privacy Policy outlines how we handle information when you access or use the Pacing iOS application. We believe in transparency and data minimization.

By accessing or using the Pacing App, you acknowledge that you have read and understood the terms of this Privacy Policy. If you do not agree with any part of this Privacy Policy, you must not access or use the Pacing App.

2. Information We Process (and What We Don’t)

We prioritize your privacy and significantly limit the data we process.

2.1. Data Stored Locally on Your Device (Not Processed by Us)

The core functionality of the Pacing App relies on data stored exclusively on your own device. This includes:

Your created workout plans and structures.
Your settings and preferences within the App.
Any workout history or logs generated through your use of the App (if applicable).

Practicable LTD does not access, collect, or store this local data on our servers. You have full control over this data. You can modify or delete it at any time using the App’s features or through standard iOS application data management (including uninstalling the App, which will remove its associated local data).

Important Note on Local Data: Because this data resides solely on your device, you are responsible for its backup and security. Practicable LTD cannot recover this local data if your device is lost, damaged, reset, or if the App is deleted. Data loss due to device failure or user action is outside of our control.

2.2. Information We Do Not Collect

Reflecting our commitment to data minimization, we do not collect, store, request, or transmit any Personally Identifiable Information (PII). This includes, but is not limited to:

Personal Details: Your name, email address, phone number, age, gender, etc.
Account Information: The App does not require user accounts or registration.
Location Data: We do not collect, track, or store your precise or approximate GPS location data.
HealthKit Data: We do not access or request data from Apple’s HealthKit.
Device Contacts, Photos, or Files: The App does not access personal files on your device.

2.3. Anonymous Information Collected Automatically (Processed by Us)

To maintain and improve the quality, stability, and functionality of the Pacing App, we collect limited, anonymous, non-personally identifiable information automatically when you use the App. Our lawful basis for processing this anonymous data under GDPR is our Legitimate Interest in understanding app usage to improve our service for all users, ensuring the impact on individual privacy is minimal due to the anonymous and aggregated nature of the data.

This anonymous data includes:

Anonymous Usage Data: Aggregated information about interactions, such as screens viewed, features used (e.g., workout creation), session duration, and UI element interactions (button taps). This data is aggregated across users and cannot identify you.
Anonymous Workout Analytics: Aggregated, non-identifiable statistical information about workout structures used within the app (e.g., types of intervals created, average number of intervals). This contains no personal metrics or location information.
Anonymous Performance Data: Anonymized technical information like crash reports (without personal context) and general device characteristics relevant to performance (e.g., OS version, device model type) for debugging and optimization.

Crucially, all automatically collected data is:

Anonymous: Not linked to any identifier that could single you out.
Aggregated: Analyzed for trends across many users.
Stripped of Personal Context: Contains no PII or location data.

3. How We Use Your Information

The strictly anonymous and aggregated information described in Section 2.3 is used solely for the following internal purposes, based on our legitimate interest:

Providing and Improving the Service: Understanding usage to identify popular features, detect areas for improvement, maintain stability, and enhance functionality.
Analytics and Performance: Analyzing statistical usage patterns, diagnosing technical issues (like crashes), optimizing performance, and ensuring service quality.
Feature Development: Guiding decisions about future updates based on aggregated user interaction patterns.

We do not use this anonymous data for advertising, user profiling, or any purpose other than improving the Pacing App.

4. Disclosure of Your Information

We do not sell, rent, or trade any information. We only share information in the following limited circumstances:

Service Providers (for Analytics): We may utilize third-party analytics services to help us process and understand the anonymous, aggregated data (Section 2.3). These providers act as Data Processors on our behalf. We ensure they are contractually obligated (including via Data Processing Agreements) to handle this data securely, maintain its anonymity, use it only for providing analytics services to us, and comply with GDPR standards. If these providers are located outside the EU/EEA, we ensure appropriate safeguards (like Standard Contractual Clauses) are in place.
Business Transfers: In the event of a merger, acquisition, financing, reorganization, or sale of assets involving Practicable LTD, the anonymous, aggregated data assets may be transferred. We will ensure the receiving party agrees to uphold the principles of this Privacy Policy regarding any transferred anonymous data.
Legal Requirements: We may disclose anonymous, aggregated information if required by law or in the good faith belief that such action is necessary to comply with a legal obligation (especially under EU or member state law), protect and defend our rights or property, prevent fraud, or protect against legal liability.

5. Data Retention

We retain the anonymous, aggregated analytics data (Section 2.3) only for as long as necessary to fulfill the legitimate purposes outlined in Section 3 (e.g., trend analysis, performance monitoring). Once no longer needed, we securely delete or further anonymize it. Data stored locally on your device (Section 2.1) is retained according to your own actions (e.g., until you delete the app or data).

6. Security

We implement reasonable technical and organizational measures designed to protect the anonymous information we process (Section 2.3) from loss, misuse, and unauthorized access or disclosure. However, no electronic transmission or storage is 100% secure. Security of the data stored locally on your device (Section 2.1) is your responsibility.

7. International Data Transfers

Practicable LTD is based in the European Union. The anonymous analytics data is processed by Posthog Cloud EU and will stay within the EU.

8. Children’s Privacy

The Pacing App is not intended for use by individuals under the age of 16 (or the applicable age of digital consent in your EU member state if lower, but not less than 13) without parental consent. We do not knowingly collect any information, anonymous or otherwise, from children under this age. If we become aware that we have inadvertently collected information from a child, we will take steps to delete it. If you are a parent or guardian and believe your child has provided us with information, please contact us at [email protected].

As Practicable LTD is based in the EU, you have certain rights under the GDPR regarding data processing.

Rights Regarding Local Data: As explained in Section 2.1, your primary workout data is stored locally. You have direct control to access, modify, and erase this data through the App or your device settings at any time. These GDPR rights are effectively exercised directly by you on your device.
Rights Regarding Anonymous Analytics Data: Regarding the anonymous data we process based on legitimate interest (Section 2.3):
- Right to Object: You have the right to object to our processing of this anonymous data based on your particular situation.
- Right to Restriction of Processing: You may have the right to request the restriction of processing under certain circumstances.
- Other Rights (Limited Applicability): Rights like access, rectification, erasure, and data portability concerning personal data are generally not applicable to the anonymous analytics data we process, as it is not linked to you and we cannot identify your specific data within the aggregated, anonymized dataset.
Exercising Your Rights: To exercise your right to object or inquire about restriction concerning the anonymous analytics data, please contact us at [email protected].
Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of data relating to you infringes GDPR.

10. Third-Party Links and Services

The Pacing App itself does not contain third-party links, but this policy may be hosted online. If you access this policy via a website that contains links, be aware we are not responsible for the privacy practices of those other sites.

11. Changes to This Privacy Policy

We may update this Privacy Policy occasionally to reflect changes in our practices, legal requirements, or App functionality. We will revise the “Last Updated” date when we do. If material changes occur, we will provide notice through appropriate means. Your continued use of the Pacing App after changes constitutes your acceptance of the revised policy. Please review this policy periodically.

12. Contact Us - Data Controller

Practicable LTD, based in the European Union, is the Data Controller for the anonymous analytics data processed under this policy.

If you have any questions, comments, concerns about this Privacy Policy, our data practices, or wish to exercise your GDPR rights (like the right to object), please contact our privacy team at:

Email: [email protected]