EU/ETA ApexPace GDPR Privacy Policy EN

ApexPace EU/ETA GDPR Privacy Policy (EN)

Privacy Policy (GDPR, EU/EEA)


Privacy Policy (GDPR, EU/ETA) (EN)

Privacy Policy: ApexPace

Last updated: 31 October 2025

This Privacy Policy describes how FellCode ("us", "we", "our") collects, uses, and protects your personal data when you use the ApexPace mobile application ("Service").

1. Data We Collect

We collect data to provide and improve the Service.

A. Data Voluntarily Provided by the User:

  • Training Data: User-inputted base pace (min/km), manually entered distances, elevation gains, and segment lengths.

  • Energy Calculator Data: Inputted paces (min/km) and corresponding carbohydrate amounts (g/h).

  • Files: GPX files that the user separately and explicitly opens. 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:

  • Subscription Data: We collect information about your subscription type (Free, Monthly, Annual) and purchase history status (e.g., PURCHASED, CANCELED) through the Google Play Billing service.
    This data includes an anonymous purchase ID, but we never see, collect, or store your personal payment information, such as a credit card number.

  • Device and Usage Analytics Data: We use the Firebase Analytics service to collect anonymous data on how the Service is used. This includes:

  • An anonymous advertising identifier or device identifier.

  • Device model, operating system, and application version.

  • General usage events (e.g., "app_open", "gpx_calculation_started", "subscription_page_opened").

  • Crash Reports: We use the Firebase Crashlytics service. If the application crashes, we collect an anonymous technical report (stack trace) and device information to diagnose and fix the problem.

  • Statutory Location Data: Upon application launch, we collect your approximate location (based on your IP address) for the sole purpose of identifying your geographical region (e.g., country).
    C. Data Stored Locally on the Device:

  • Settings: We store your chosen theme (light/dark/system) 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.

2. Purpose of Data Processing (Legal Basis)

We process your data for the following purposes and on the following legal bases:

  • To Provide the Core Functionality of the Service (Legal Basis: Explicit Consent, GDPR Art. 9)
    We use your Training Data, Energy Calculator Data, and GPX files to calculate the pace predictions, segment times, and energy estimates you request.
    Because this data, when combined, may constitute data concerning health, its processing is based on your explicit consent, which we will ask for separately before you use these features.

  • To Administer the Service (Legal Basis: Performance of a Contract)
    We use your Subscription Data to manage your subscription and provide you with access to paid features.

  • To Comply with Legal Obligations (Legal Basis: Legal Obligation)
    We use your approximate location data to identify your country and display the correct, geographically-specific Terms of Use and Privacy Policy (e.g., the EU/EEA version).

  • To Improve Our Service (Legal Basis: Legitimate Interest)
    We use anonymous analytics data (Firebase) to understand which features are used, to optimize the user interface, and to enhance the overall user experience.
    We use crash reports (Crashlytics) to find and fix bugs and to improve the stability of the application.

3. Data Sharing and Transfer (Third Parties)

We do not sell or rent your personal data. We share data only with the following processors, who are essential for the operation of the Service:

  • Google (Google Play & Firebase):

  • Google Play Billing: Processes all payment transactions and subscription data. We never see or store your credit card information.

  • Firebase Analytics & Crashlytics: Processes anonymous usage and crash data on its servers located in the United States.

  • RevenueCat (If used for subscription management):

  • We use the RevenueCat service to manage and validate subscriptions. RevenueCat processes anonymous subscription identifiers and purchase events to provide us with analytics and to ensure your subscription is valid.
    Transfer of Data Outside the EU/EEA:
    The servers of the aforementioned partners (Google, RevenueCat) may be located outside the EU/EEA, primarily in the United States.
    All data transfers are based on the European Commission's approved Standard Contractual Clauses (SCCs) or other lawful transfer mechanisms that ensure an adequate level of data protection.

4. Data Security

We take data security seriously. All data transmission between our application and third-party servers (analytics, payment data) is protected using industry-standard encryption technology (SSL/TLS).

Locally stored data is kept in your device's secure, application-specific storage.

5. Data Retention

  • Local Data: Settings data and consent records are retained on your device until you uninstall the application.

  • Remote Data: Anonymous analytics data is retained in the Firebase service for product development purposes (e.g., for 26 months).
    Subscription data is retained for as long as your subscription is active and for the period required by accounting laws.

6. User Rights (GDPR)

You have the following rights regarding your personal data:

  • Right of Access: The right to request a copy of the data we have collected about you.

  • Right to Rectification: The right to request the correction of inaccurate data.

  • Right to Erasure ('Right to be Forgotten'): The right to request the deletion of your data under certain conditions.

  • Right to Restriction of Processing: The right to request the restriction of the processing of your data in certain situations.

  • Right to Data Portability: The right to receive certain data you have provided in a machine-readable format and to transmit it to another controller.

  • Right to Object to Processing: You may object to the collection of analytics data based on our legitimate interest through the application's settings menu.

  • Right to Lodge a Complaint: The right to lodge a complaint with your local data protection authority if you believe we have violated your rights.
    You may exercise the rights listed above by contacting us via the contact details provided in Section 9, unless otherwise specified.

7. Children's Privacy

Our Service is not directed to individuals under the age of 16. We do not knowingly collect personal data from children under 16.

8. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes within the application or by email.

9. Data Controller's Contact Information

If you have any questions about this Privacy Policy, please contact:

FellCode / Toni Limnell

Business ID: 2625890-7

Contact: privacy@fellcode.com