Privacy

1. Summary

2. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

We have not appointed a data protection officer as we are not legally required to do so (Art. 37 GDPR, Section 38 BDSG). For any privacy questions, please contact us at the email address above.

3. Visiting this website

3.1 Hosting and server logs (Cloudflare)

This website is served via Cloudflare Pages, provided by Cloudflare, Inc., USA ("Cloudflare"). Cloudflare runs a global content delivery network and protects the website against attacks. When you visit, Cloudflare processes technically necessary data sent by your browser:

• IP address, date and time of access,
• requested page or file, HTTP status code and amount of data transferred,
• referrer URL, browser type and version, operating system.

Purpose: delivering the website, stability, security (e.g. preventing DDoS attacks and abuse) and troubleshooting. Legal basis: Art. 6(1)(f) GDPR; our legitimate interest is a secure, fast and error-free service. Where Cloudflare sets or reads strictly necessary security cookies (e.g. __cf_bm), this is based on Section 25(2) no. 2 TDDDG. We do not use this data for marketing and do not combine it with other data.

Cloudflare acts as our processor (Art. 28 GDPR) under a data processing addendum. Where the provider is certified under the EU-U.S. Data Privacy Framework, transfers are based on the European Commission's adequacy decision of 10 July 2023 (Art. 45 GDPR). In addition, or otherwise, we have concluded EU Standard Contractual Clauses with the provider (Art. 46(2)(c) GDPR). More information: cloudflare.com/privacypolicy.

3.2 No cookies, no tracking, no external content

We use no analytics or marketing cookies and no tracking tools on this website. Fonts, images and scripts are loaded from our own server, so no data is sent to third parties such as Google when you view a page. If you follow a link to the Apple App Store, Apple's privacy policy applies from then on.

Time calculator (splitwerk.app/en/calculator): Your answers in the time calculator are processed only locally in your browser; they are not transmitted to us or to third parties and are not stored.

3.3 Share links (splitwerk.app/s/…)

When someone shares a result card from the app, the message contains the link splitwerk.app/s. The link contains no result data; times only appear on the image that the sharing person sends themselves. Section 3.1 applies when the link is opened. If the app is installed, iOS opens the link directly in the app.

4. App: data on your device

Splitwerk works without a user account. The following information is stored and processed exclusively locally in the app on your iPhone, to show you your prediction, heatmap, training plan, pacing plan and progress:

• onboarding answers (e.g. goal, race and race date, division, 5 km time, weekly running, background, station check, age band, optional body weight, equipment, training days),
• answers to the short health check (yes/no questions),
• training logs, perceived exertion (RPE), readiness, benchmarks, race results, doubles information about your partner (e.g. a name or nickname and benchmark values),
• settings (language, reminder time) and your privacy choices.

This data does not leave your device and is not transmitted to us or to third parties. We have no access to it. All calculations (e.g. the finish-time prediction) run entirely on your device. Some of this information may be health data within the meaning of Art. 9 GDPR – which is exactly why it stays local.

Device backups: if you use iCloud Backup or local backups of your iPhone, app data may be included in those backups. You control this in iOS settings; it is processing by Apple on your behalf, and we have no access to it.

Deletion: you can delete all locally stored data at any time in the app under "More" → "Delete all data", or by deleting the app.

5. App: download and purchase via Apple

The app is distributed via the Apple App Store. You take out subscriptions via the App Store; in the EU the App Store is operated by Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland. Apple processes, as an independent controller, among other things your Apple ID, payment details and purchase history. We do not receive payment details or your name from Apple – only the transaction information needed to manage subscriptions, plus aggregated statistics (e.g. downloads and purchases per country).

If you have enabled "Share with App Developers" in iOS, Apple also provides us with crash reports and usage statistics without direct personal identifiers. Details: apple.com/legal/privacy.

6. App: subscription management with RevenueCat

To manage subscriptions (purchase, free trial, renewal, restoring purchases, unlocking Pro features) we use RevenueCat, provided by RevenueCat, Inc., USA. The following data is processed:

• a randomly generated, pseudonymous app user ID (no name, no email),
• App Store purchase data (product, price, currency, purchase date, trial, renewal and cancellation status, store country, transaction IDs),
• technical data (app version, iOS version, device model, language, IP address for transmission).

Purpose: providing and billing your subscription. Legal basis: Art. 6(1)(b) GDPR (performance of a contract).

Only with your consent does the app additionally pass identifiers to RevenueCat, so that purchases can be attributed in the respective evaluation (legal basis then Art. 6(1)(a) GDPR, Section 25(1) TDDDG):

• for analytics, the pseudonymous PostHog identifier (section 8),
• for marketing measurement (section 9), the anonymous Meta ID, the identifier for vendors (IDFV), the advertising identifier (IDFA) and your device's IP address.

If you withdraw a consent or choose "Delete all data" in the app, the app removes the relevant identifiers from RevenueCat again.

No Apple Ads attribution token (AdServices) is collected; the app gives RevenueCat no data for attributing Apple Search Ads campaigns.

RevenueCat is our processor (Art. 28 GDPR). Where the provider is certified under the EU-U.S. Data Privacy Framework, transfers are based on the European Commission's adequacy decision of 10 July 2023 (Art. 45 GDPR). In addition, or otherwise, we have concluded EU Standard Contractual Clauses with the provider (Art. 46(2)(c) GDPR). More information: revenuecat.com/privacy.

7. App: consent

When you first open the app, we ask whether you consent to analytics (section 8) and marketing measurement (Meta) (section 9). For marketing measurement, iOS additionally asks for your tracking permission (App Tracking Transparency, ATT). All options are optional; the app works fully without consent. Your choice and its time are stored locally on your device so that we can respect and demonstrate it (Art. 6(1)(c) in conjunction with Art. 7(1) GDPR).

Withdrawal: you can withdraw your consent at any time with effect for the future in the app under "More" → "Privacy". You can also change tracking permission (ATT) in iOS under Settings → Privacy & Security → Tracking. Withdrawal does not affect the lawfulness of processing before withdrawal.

8. App: product analytics with PostHog (consent only)

If you consent to analytics, we use PostHog, a service of PostHog Inc., USA, with data stored in the EU (data centre in Frankfurt am Main, Germany). This helps us understand how the app is used, find problems in the flow (e.g. where people drop out of onboarding) and test variants of copy and screens.

Data processed: a randomly generated pseudonymous identifier; in-app events (e.g. screen viewed, onboarding step completed, paywall viewed, trial started, app opened); assigned test variants; app version, language, subscription status (yes/no); device model, iOS version, screen size. The IP address is used only for transmission; PostHog discards it and no location is derived from it. Never sent: your times, paces, weights, health check answers, age information or any other training or health data. We do not use session replay. In addition, RevenueCat sends subscription events (e.g. trial started, subscription renewed or cancelled) with the pseudonymous identifier to PostHog, so we can see how many trials turn into subscriptions. If you withdraw consent, collection stops immediately and the app removes the identifier from RevenueCat.

Legal basis: your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). Retention: event data is deleted after 12 months at the latest. PostHog is our processor (Art. 28 GDPR). Access from the USA (e.g. for support and maintenance) cannot be ruled out; where the provider is certified under the EU-U.S. Data Privacy Framework, transfers are based on the European Commission's adequacy decision of 10 July 2023 (Art. 45 GDPR). In addition, or otherwise, we have concluded EU Standard Contractual Clauses with the provider (Art. 46(2)(c) GDPR). More information: posthog.com/privacy.

9. App: marketing measurement with Meta and App Tracking Transparency (consent only)

We advertise Splitwerk on Instagram and Facebook, among other channels. If you consent to "Marketing measurement (Meta)" and select "Allow" in the iOS App Tracking Transparency (ATT) prompt, the app initializes the software development kit (SDK) of Meta Platforms Ireland Ltd., Merrion Road, Dublin 4, D04 X2K5, Ireland ("Meta"). If either permission is missing, the app does not initialize the SDK and sends no events, no Meta ID and no device identifiers to Meta.

Purpose: measuring whether our ads lead to trials and subscriptions (ad attribution), and showing ads to people likely to be interested in Splitwerk. Data processed:

• the event "registration completed" (CompletedRegistration) – once per install, when you reach your finish-time prediction, without further details; the app sends it via the SDK,
• trial starts and subscription purchases and renewals (incl. product, price and currency); RevenueCat sends these events server-to-server via Meta's Conversions API, and only if you have consented and allowed tracking,
• the anonymous Meta ID (an app identifier generated by the Meta SDK on your device), your iPhone's advertising identifier (IDFA) and the identifier for vendors (IDFV),
• technical data (device model, iOS version, app version, language, time zone, IP address).

The app sends no other events to Meta; in particular, it does not report installs or app launches (the SDK's automatic event logging is switched off). Never sent: your times, quiz answers, training or health data.

Legal basis: your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). We and Meta are joint controllers for the collection and transmission of the data to Meta (Art. 26 GDPR); the agreement is available at facebook.com/legal/controller_addendum. Meta is solely responsible for any further processing. Meta may transfer data to Meta Platforms, Inc. in the USA, which is certified under the EU-U.S. Data Privacy Framework (Art. 45 GDPR); Meta also uses EU Standard Contractual Clauses. More information, including your rights against Meta: facebook.com/privacy/policy.

ATT and withdrawal: if you decline the ATT prompt, marketing measurement stays off. If you withdraw your consent in the app, the app stops sending data to Meta immediately and removes the Meta ID and the device identifiers (IDFA, IDFV, IP address) from RevenueCat, so RevenueCat sends no further events to Meta. If you revoke tracking permission in the iOS settings, the same happens the next time you open the app at the latest. Meta processes data it has already received according to its own retention periods. The app works fully either way.

10. App: other features

10.1 Reminders (local notifications)

Training reminders, the weekly check-in, the reminder before your trial ends and the race countdown are scheduled as local notifications directly on your iPhone. There is no push server and no data is sent to us for this. You can allow or turn off notifications at any time in iOS settings.

10.2 Sharing

Result cards are created as images on your device. You decide via the iOS share sheet whether, with whom and via which app you share them; the provider of the chosen app is responsible for its processing. If you save a card to your photos, iOS asks for your permission first.

10.3 Ratings and voice cues

If the app asks you for a rating, it uses the standard iOS feature; Apple processes any rating you submit. Voice cues in the workout player are generated by your iPhone's built-in speech output.

11. Contacting us by email

If you write to support@splitwerk.app, we process your email address, your name (if provided) and the content of your message to answer your request. Legal basis: Art. 6(1)(b) GDPR where your request relates to a contract, otherwise Art. 6(1)(f) GDPR (our legitimate interest in answering). Emails to this address are forwarded via Cloudflare Email Routing to our mailbox at an external email provider (processor). Please do not send us health data by email. We delete your request once it has been resolved, and after 2 years at the latest, unless statutory retention obligations apply.

12. Recipients and processors

We only share personal data as described in this policy. Recipients are:

Beyond that, we only disclose data where we are legally required to do so (e.g. to public authorities).

13. Transfers to third countries

Some of the providers above are based in the USA or may access data from there. The USA is considered to provide an adequate level of data protection for companies certified under the EU-U.S. Data Privacy Framework (European Commission adequacy decision of 10 July 2023, Art. 45 GDPR). Where a provider is not certified, transfers are based on EU Standard Contractual Clauses (Art. 46(2)(c) GDPR) with supplementary measures. You can request a copy of the safeguards from us.

14. Retention periods

• Local app data (including your privacy choices): until you delete it in the app or remove the app.
• Server logs (Cloudflare): only as long as needed for delivery and security; we do not keep log files ourselves.
• Subscription data (RevenueCat): for the duration of your subscription and thereafter where statutory retention obligations apply (e.g. Section 147 AO, Section 257 HGB), or until you request deletion and no obligation prevents it.
• Attribution identifiers at RevenueCat (PostHog identifier, Meta ID, IDFA, IDFV, IP address): until you withdraw the respective consent or choose "Delete all data" in the app.
• Analytics data (PostHog): 12 months at most; collection stops immediately on withdrawal.
• Marketing measurement (Meta): according to Meta's retention periods; transmission stops immediately on withdrawal.
• Support emails: until resolved, 2 years at most, subject to statutory retention obligations.

15. Your rights

You have the following rights regarding your personal data:

• access (Art. 15 GDPR),
• rectification (Art. 16 GDPR),
• erasure (Art. 17 GDPR),
• restriction of processing (Art. 18 GDPR),
• data portability (Art. 20 GDPR),
• withdrawal of consent with effect for the future (Art. 7(3) GDPR).

Simply email support@splitwerk.app. As we do not keep user accounts, we can only identify you by the information you give us (e.g. the order ID from Apple's purchase receipt); only you can view and delete the data stored locally on your device.

16. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular in the member state of your habitual residence, place of work or place of the alleged infringement. The supervisory authority responsible for us is: the State Commissioner for Data Protection and Freedom of Information Baden-Württemberg (Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg), Heilbronner Straße 35, 70191 Stuttgart, Germany.

17. Further information

Obligation to provide data: you are not legally or contractually obliged to provide data. Without the data needed for a purchase, however, Apple and RevenueCat cannot process a subscription.

No automated decision-making: no automated decision within the meaning of Art. 22 GDPR takes place. The finish-time prediction is calculated locally, serves only your training and has no legal or similarly significant effect.

Minimum age: only people aged 16 or over can give consent to analytics and marketing measurement themselves (Art. 8 GDPR). If you are younger, please leave these options switched off.

Changes: we update this policy when the app, the website or the law changes. The version published here applies.

Last updated: 23 September 2026

This English version is provided for convenience. In case of discrepancies, the German version applies.