Latest version: August 22, 2023
Privacy is a fundamental human right. That’s why we have developed FitWoody to be as respectful as possible with your privacy, intimacy, and your personal data. Your data is yours, and with FitWoody, you have full control over them.
2. Who are we?
FitWoody is an application that has been developed by the commercial company CORI HEALTH & CARE, S.L.U., with Tax Identification Number (NIF) B01740364, and located in Spain, at Diputación Foral de Álava 4, 3rd floor, Postal Code 01001 of Vitoria-Gasteiz (Álava).
CORI HEALTH & CARE, S.L.U. is registered in the Álava Commercial Registry, in Volume 1705, Folio 221, Sheet VI-20033, Entry 1st.
In accordance with this, we inform you that, from the point of view of data protection regulations, the controller of the processing is the company, with the previously indicated data.
3. What data do we process about you?
We do not have access to the personal data that are entered manually or automatically into FitWoody. Remember, your data is yours, and you have control over them. FitWoody is an application that we have developed so you can track your daily activity, sleep, and workouts.
3.1. Apple Health Data
FitWoody uses the APIs provided by Apple to read and/or write the data that is found in the Apple Health application (https://www.apple.com/lae/privacy/) on your device. Specifically, for proper functioning, FitWoody requires reading the following:
- Pedaling cadence.
- Aerobic capacity.
- Walking/running distance.
- Biking distance.
- Snow sports distance.
- Wheelchair distance.
- Activity energy.
- Walking stability.
- Date of birth.
- Heart rate.
- Resting heart rate.
- Respiratory rate.
- Blood glucose.
- Exercise minutes.
- Standing minutes.
- Blood oxygen.
- Floors climbed.
- Biking power.
- Workout routes.
- Wrist temperature.
- Heart rate variability.
- Biking speed.
It also requires write access to:
- Workout routes.
Apple Health data will only be used to provide daily activity, sleep, or exercise services related to the App. In any case, they will not be used for marketing, advertising, or data mining based on usage, even by third parties.
FitWoody cannot read and/or write to Apple Health without your express consent. The application accesses your health data locally, and they are never stored permanently or temporarily in FitWoody. All data is processed locally on your device and is not sent to any own or third-party servers.
You can find more information about Apple Health at the following link: https://support.apple.com/es-es/guide/iphone/iphbb8259c61/16.0/ios/16.0
3.2. Location Data
If you view and/or log your outdoor workouts with FitWoody, we may use your location data to show you a map with the route of your training.
FitWoody cannot access your location data without your express consent. The application accesses your location data locally during the workout and then stores them in Apple Health. It can access them whenever the user gives permission, as described in point 3.2.
The processing of location data is done locally and is not transmitted to any proprietary or third-party servers. In any case, they will not be used for marketing, advertising, or data mining based on usage, even by third parties.
3.3. Technical and Usage Data
Finally, we use analytics services on the usage by users of FitWoody, which allows us to detect and identify improvements to be made in the App. For this, we use TelemetryDeck and RevenueCat, although the data collected by these services are completely anonymous. When a user installs the app, TelemetryDeck and RevenueCat assign each user a randomly and anonymously generated ID, so we cannot know the real identity of that user. This way, we can know, for example, the sessions that are being that ID, which allows us to know, for example, that a user ID has made a subscription to FitWoody or the sessions carried out in a day.
You can also consult TelemetryDeck’s terms of service at the following link: https://telemetrydeck.com/pages/termsofservice.html
You can also consult RevenueCat’s terms of service at the following link: https://www.revenuecat.com/terms
You can consult the Data Processing Addendum at this link: https://www.revenuecat.com/dpa
4. Principles Related to Processing According to the General Data Protection Regulation (GDPR)
At CORI HEALTH & CARE, S.L.U., we are clear that the most important thing is the privacy of FitWoody users. Therefore, from the beginning, we have conceived and developed it taking into account compliance with the principles required by the General Data Protection Regulation. But how do we comply with these principles? We explain it below:
- Principle of purpose limitation: as we have previously pointed out, we do not collect personal data from FitWoody users as these are stored only on their own devices. We only use anonymous data from users for analytical and statistical purposes, in order to detect areas for improvement in the application, but since they are anonymous, we cannot identify any user, which means that we do not actually process personal data from users.
- Principle of data minimization: as we have said in the previous paragraph, we respect this principle of data minimization to the extent that, unlike other applications, we do not process any personal data of FitWoody users. The only assumption of processing is regarding anonymous usage data of the application.
- Principle of accuracy: we do not consider this principle applicable to us since, by not processing personal data from users, obviously, we cannot keep accurate and up-to-date data that is not processed.
- Principle of limitation of the retention period: this principle, which requires that personal data not be kept in a way that allows the identification of the interested parties for no longer than necessary for the purposes of processing personal data, may be kept for longer periods as long as they are processed exclusively for purposes of public interest archiving, scientific or historical research purposes or statistical purposes. We do not process personal data from FitWoody users; we only have anonymized data for analytical purposes to detect areas of improvement, keeping them only during the period necessary to analyze them and, if applicable, implement them, subsequently proceeding to their deletion.
- Principle of integrity and confidentiality: at CORI HEALTH & CARE, S.L.U., we apply appropriate technical and organizational measures to ensure adequate security of personal data, including protection against unauthorized or unlawful processing and against loss, destruction, or accidental damage. To determine the security measures we apply, we conduct risk assessments, which we review periodically. Likewise, we guarantee the confidentiality of our information to which all people and third parties who, in one way or another, provide us services, signing the corresponding confidentiality contract.
- Principle of proactive responsibility: in addition to applying technical and organizational security measures, we document and review them to be able to guarantee and accredit that the processing we do complies with the requirements of the General Data Protection Regulation.
One of the most important premises for us, along with the privacy of FitWoody users, is security. Therefore, we implement the highest security measures within our reach and as allowed by the existing technology at any given time. Additionally, we conduct periodic reviews to improve the security of the app.
In any case, FitWoody complies with the security requirements demanded by Apple for developers.
8. Information on the Processing of Personal Data
In accordance with the provisions of the General Data Protection Regulation and Organic Law 3/2018, of December 5, on Personal Data Protection and the Guarantee of Digital Rights, we inform you of the following issues regarding the treatment (or lack thereof) we apply to the personal data of FitWoody users:
Data Controller: CORI HEALTH & CARE, S.L.U., with tax identification number B01740364, and address at Diputación Foral de Álava 4, 3rd floor, Zip Code 01001, Vitoria (Álava).
Personal Data Collected: as previously indicated, CORI HEALTH & CARE, S.L.U. does not collect personal data from FitWoody users; we only process anonymous and random ID data, not linked to the user, but rather related to the device ID and usage data, interaction with FitWoody, all for analytical purposes aimed at detecting and implementing improvements.
Purpose of Processing: as we just mentioned, the only data we process from FitWoody users are not related to them but are completely anonymous and used solely for the purpose of analyzing the use of the application to detect and implement improvements in it.
Legitimization of Processing: the legal basis that legitimizes the processing of the previously indicated anonymous data is that it is necessary to satisfy our legitimate interests in improving the functionality, features, and performance of FitWoody.
Data Recipients: personal data from FitWoody users are not communicated to any third party, as we do not have access to them.
In any case, for some matters, we use third-party services that act as data processors, with whom we have signed the corresponding data processing contract in accordance with the provisions of Article 28.3 of the GDPR.
International Data Transfers: we inform you that we do not make international transfers of personal data.
Data Retention Period: we only retain anonymous user data for the period necessary to analyze and, if applicable, implement issues and functionalities that can improve FitWoody, after which they will be deleted.
Rights of the Interested Party Regarding the Processing of Their Data: you have all the information about this in the section «What rights do you have regarding the processing of your personal data?»
Complaint to the Control Authority: you have all the information about this in the section «What rights do you have regarding the processing of your personal data?»
9. What rights do you have regarding the processing of your personal data?
Right of access: In order to know and verify the legality of the processing, you can request confirmation at any time as to whether CORI HEALTH & CARE, S.L.U. is processing your personal data, and if so, we will inform you, among other things, about the data we are processing, its purpose, origin, expected retention period, and, if applicable, recipients or categories of recipients.
Right to rectification: This right acknowledges the possibility to request the rectification of personal data that is inaccurate or completion of those that are incomplete, including through an additional statement. In such a case, you must indicate in your request which data you refer to and the correction to be made, if necessary, providing supporting documentation for the inaccuracy or incomplete nature of the data being processed. However, since we do not have or process your personal data, this is a right that we cannot address. You can rectify or modify your personal data in FitWoody yourself.
Right to erasure (“right to be forgotten”): You can request that your personal data be erased and cease to be processed if they are no longer necessary for the purposes for which they were collected or otherwise processed, you withdraw your consent, they have been processed unlawfully, or they must be erased to comply with a legal obligation.
In this case, the same applies as we do not have access to your personal data and cannot delete them, but you can do so in FitWoody and even delete the application from your device.
Right to restriction of processing: In this case, CORI HEALTH & CARE, S.L.U. will only retain your personal data for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of significant public interest. Here too, as we do not have your personal data, we cannot comply with this right, since the data are on your device; we have no ability to limit their processing.
Right to data portability: This right allows you to request that we provide you or another controller you indicate with your personal data in a structured, commonly used, and machine-readable format. Again, we cannot provide any data because we do not have access to them, but you can download or export them to other services yourself.
Right to object: In this case, you have the right to have us cease processing your personal data as you indicate unless we have to continue processing them for compelling legitimate reasons or for the establishment, exercise, or defense of potential claims. However, we also cannot comply with a request of this type because we do not have your data. That said, if you no longer wish to use the application, you can delete your data and even remove it from your device.
How to exercise your data protection rights? To exercise your rights, you must send us a written request, indicating the right you wish to exercise, to CORI HEALTH & CARE, S.L.U., at Diputación Foral de Álava 4, 3rd floor – Zip Code 01001, Vitoria (Álava) or by sending an email to email@example.com, always including a photocopy of your ID.
CORI HEALTH & CARE, S.L.U. will respond to all requests within the deadlines and conditions required by current regulations on personal data protection.
In any case, if you believe that we have not adequately processed your personal data or have not properly addressed the exercise of your data protection rights, you can file a complaint with the Spanish Data Protection Agency, either through its electronic headquarters or at its address, Jorge Juan Street, No. 6, Zip Code 28001, Madrid.
You can find more information about data protection rights and complaints to this Control Authority at www.aepd.es.
10. Cookies and other similar technologies
However, as we pointed out in the third clause, we use the services of TelemetryDeck and RevenueCat to analyze, anonymously, the use of the application to identify and implement improvements in FitWoody.
12. Applicable Regulations
13. We Resolve Your Doubts