UK Privacy Policy EN
Privacy Policy: ApexPace (United Kingdom)
**Last Updated:** 5 August 2026
This Privacy Policy describes how FellCode ("we", "us", "our") collects, uses, and protects your personal data when you use the ApexPace mobile application ("Service").
We are committed to protecting your privacy and processing your data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Data Controller
For the purposes of UK data protection law, the Data Controller is:
**FellCode / Toni Limnell**
Contact: privacy@fellcode.com
2. Data We Collect
We collect data to provide and improve the Service.
A. Data Provided Voluntarily by the User:
* **Exercise Data:** The user's entered base pace (min/km), manually entered distances, elevation gain, and segment lengths.
* **Energy Calculator Data:** Entered paces (min/km) and corresponding carbohydrate amounts (g/h).
* **Files:** GPX files opened explicitly and deliberately by the user. These files contain GPS location routes, elevation data, and potential timestamps.
* *These files are processed only locally on your device and are not uploaded to our servers.*
B. Data Collected Automatically:
* **Tip Jar / Purchase Data:** Information about voluntary in-app purchases (tips, such as energy gels or coffee) and purchase history status via the Google Play Billing service. This data includes an anonymous purchase ID and product tokens, but we never see, collect, or store your personal payment information, such as a credit card number.
* **Device and Usage Analytics Data:** We use Firebase Analytics to collect anonymous data about how the Service is used.
* **Crash Reports:** We use Firebase Crashlytics. If the application crashes, we collect an anonymous technical report and device data to diagnose and fix the problem.
* **Approximate Location Data:** Upon launching the application, we collect your approximate location (based on IP address) solely to identify your geographic region (e.g., country).
C. Data Stored Locally on the Device:
* **Settings:** We store your chosen theme and language in your device's secure storage.
* **Consent:** We store a record that you have accepted our Terms of Use and this Privacy Policy.
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3. Purpose of Processing and Lawful Basis
We process your data for the following purposes and on the following lawful bases under the UK GDPR:
* **To Provide the Core Functionality of the Service (Basis: Explicit Consent)**
* We use your Exercise Data, Energy Calculator Data, and GPX files to calculate the pace predictions, segment times, and energy estimates you request.
* As this data, when combined, may constitute data concerning health, its processing is based on your explicit consent.
* **To Process Voluntary Support (Basis: Performance of a Contract / Legitimate Interest)**
* We use your Tip Jar purchase data to process voluntary contributions made through Google Play.
* **To Comply with a Legal Obligation (Basis: Legal Obligation)**
* We use your Approximate Location Data to identify your country and display the correct, geographically-specific legal terms.
* **To Improve the Service (Basis: Legitimate Interest)**
* We use anonymous analytics data and crash reports to understand how the Service is used and to improve its stability and user experience.
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4. Data Sharing and Transfers
We do not sell or rent your personal data. We share data only with the following data processor, which is essential for the operation of the Service:
* **Google (Google Play & Firebase):** Processes voluntary tip payments, purchase data, and anonymous analytics and crash data.
International Data Transfers:
The servers of our partner (Google) may be located outside the United Kingdom, primarily in the United States.
All transfers of personal data from the United Kingdom are based on appropriate safeguards under Article 46 of the UK GDPR. These mechanisms include the UK's International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses (EU SCCs), which ensure your data is protected to a standard equivalent to that in the UK.
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5. Data Security
All data transmission between our application and third-party servers is secured using industry-standard encryption technology (SSL/TLS).
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6. Data Retention
We retain data only for as long as necessary.
* **Analytics Data:** Retained for a maximum of 26 months.
* **Purchase Data:** Transaction records are retained as required by standard accounting and tax laws via Google Play.
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7. Your Data Protection Rights
Under UK data protection law, you have the following rights regarding your personal data:
* The right of access
* The right to rectification
* The right to erasure ("the right to be forgotten")
* The right to restriction of processing
* The right to data portability
* The right to object to processing (you can opt-out of analytics collection via the app's settings menu)
* **The right to lodge a complaint:** You have the right to lodge a complaint with the Information Commissioner's Office (ICO), which is the UK's supervisory authority for data protection ([www.ico.org.uk](https://www.ico.org.uk)).
You can exercise your rights by contacting us via the contact details provided in Section 9.
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8. Children's Privacy
Our Service is not directed at children under the age of 13. We do not knowingly collect personal data from children under 13.
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9. Contact Us
If you have any questions, please contact:
**FellCode / Toni Limnell**
Contact: privacy@fellcode.com