Privacy Policy – TRAININGG

Quick note: This Privacy Policy explains how Nico Ettlinger – Digital Solutions (“we”, “us”, or “Service Provider”) collects, uses, and protects personal data when you use the TRAININGG mobile application (“App”).
The App is offered as a Freemium Software-as-a-Service (SaaS) product distributed through the Apple App Store and Google Play Store.
It is intended for use as is and requires no separate web registration flow.

• Privacy Policy – TRAININGG
  • 1. Data We Collect
    • 1.1 Automatically collected data
    • 1.2 Authentication data (Firebase Authentication)
    • 1.3 Training and app data (Firebase Realtime Database)
    • 1.4 Third-party SDKs
  • 2. Purpose and Legal Bases (GDPR / UK DPA)
  • 3. Children’s Privacy
  • 4. Data Sharing
  • 5. International Transfers
  • 6. Retention Periods
  • 7. User Rights (GDPR / UK / LGPD)
  • 8. California Privacy (CCPA / CPRA)
  • 9. Data Security
  • 10. Data Deletion & Account Deletion
  • 11. Updates to this Policy
  • 12. Contact

Controller: Nico Ettlinger – Digital Solutions (sole proprietorship)
Address: Am Seeacker 19, 93326 Abensberg, Germany
Email: [email protected]
Effective Date: 1 November 2025

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1. Data We Collect

1.1 Automatically collected data

When you install or use the App, certain technical information is automatically collected:

• Device model, OS version, language, and time zone
• App version, screens visited, session duration
• Crash logs and performance metrics via Firebase Crashlytics
• IP address (short-term, for security and diagnostics)
• Approximate device location (country-level only, no GPS tracking)

This information is pseudonymized or aggregated and cannot directly identify you.

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1.2 Authentication data (Firebase Authentication)

If you sign in using Sign in with Apple or Sign in with Google, Firebase Authentication creates a pseudonymous user account.

Collected data includes:

• Firebase User ID
• Apple or Google identity token (secure and non-reversible)
• Authentication timestamps (registration, last login)

We do not store passwords, direct emails from Apple/Google (Apple private relay), or any billing information.

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1.3 Training and app data (Firebase Realtime Database)

The App stores certain user-entered or app-generated data in the Firebase Realtime Database (RTDB), such as:

• Workout plans
• Logged workouts and exercise history
• Performance metrics (e.g., estimated rep-max values)
• Body measurements (e.g., weight, height, body fat, age)
• App settings and preferences

These entries are linked exclusively to your Firebase User ID.

Note: Body measurements and training metrics may constitute health data under GDPR when used for assessing fitness, training progress, or physical condition.

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1.4 Third-party SDKs

All providers act as data processors under GDPR-compliant agreements.

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2. Purpose and Legal Bases (GDPR / UK DPA)

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3. Children’s Privacy

The App is not intended for children under 16 in the EU (or under 13 in the U.S.).
We do not knowingly collect data from minors.
If you believe your child has submitted data, contact [email protected] and we will delete it promptly.

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4. Data Sharing

We share data only in the following cases:

• With processors listed in § 1.4
• With authorities, where required by law
• As part of corporate restructuring (merger, acquisition), ensuring equivalent privacy safeguards

We do not sell or rent personal data.

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5. International Transfers

Firebase, Expo, and RevenueCat may process data in countries outside the EU/EEA (e.g., the U.S.).
Transfers occur under EU Standard Contractual Clauses (SCCs) or equivalent safeguards.

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6. Retention Periods

After retention, data is deleted or anonymized.

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7. User Rights (GDPR / UK / LGPD)

You have the right to:

• Access (Art. 15 GDPR)
• Rectify (Art. 16)
• Erase (Art. 17)
• Restrict or object to processing (Art. 18–21)
• Data portability (Art. 20)
• File a complaint with a supervisory authority

Brazilian users have equivalent rights under LGPD Arts. 17–22.

Requests may be submitted to [email protected]; we respond within 30 days.

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8. California Privacy (CCPA / CPRA)

For California residents:

• We do not sell personal information.
• You may request access or deletion of information about your device or activity.
• We do not discriminate against users for exercising their rights.

Submit requests to [email protected] with subject “CCPA Request”.

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9. Data Security

We implement industry-standard security measures:

• HTTPS/TLS encrypted communication
• Strict Firebase security rules
• Authentication safeguards
• Limited internal access to pseudonymized data
• Regular updates of SDKs and infrastructure

No system can guarantee absolute security.
If a data breach occurs, we will notify affected users and authorities as required.

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10. Data Deletion & Account Deletion

You may:

• Uninstall the App to stop all future data collection, and
• Request deletion of your Firebase account and all associated training data.

Account & data deletion can be requested at:

https://www.trainin.gg/app/account-deletion

We delete personal and training-related data within 30 days, unless a longer period is legally required.

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11. Updates to this Policy

The latest version is always available at:
https://www.trainin.gg/app/privacy

Material changes will be announced in-app before becoming effective.

Last updated: 17 November 2025

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12. Contact

For questions or concerns regarding privacy:

Nico Ettlinger – Digital Solutions
Am Seeacker 19
93326 Abensberg
Germany
Email: [email protected]