Privacy policy

1. Who is responsible (data controller)

The data controller is Simone Orazio Scionti, Via Tito Manlio Manzella 5, Catania, Italia. For anything about your data, including exercising your rights, write to info@apexlaps.app.

2. Data we process

• Location (GPS), only while you record a session or look for nearby tracks. Used to map the track, detect laps and sectors and compute distance and speed. Apex asks for full accuracy only while you record.
• Altitude and motion data (barometer, motion sensor), during a session, to compute elevation change.
• Your sessions (laps, sector times, the path ridden) and your library of tracks, saved on your phone and synced to our servers so you don't lose them.
• Tracks you map: shape, name, sector boundaries and a random identifier that says which rider can edit the track. They go into a catalog that other riders can read, so they can use the track too.
• A random identifier: on first launch the app creates an anonymous account, with no sign-up, to keep your data separate from other riders' data. It is not linked to your name, Apple ID or phone number.
• Usage statistics: screens and buttons used, app and system version, language and plan. They carry no account identifier, only a random code that exists while the app is open, so they can't be traced back to you.
• Beta tester form on this website: email, what you ride and your opinion of Apex (both optional), and the language of the page.
• Website: this site uses no cookies and no analytics or advertising tools. Our hosting provider (Google Firebase Hosting) may record technical data such as your IP address in server logs, for security and to deliver the pages.

3. Why we use it and on what legal basis

• Record sessions, time laps and show your results: performance of the service you asked for (Art. 6(1)(b) GDPR). For location, motion and altitude data we also rely on your consent, given through the iOS permission (Art. 6(1)(a)).
• Sync and back up your sessions and library: performance of the service (Art. 6(1)(b)).
• Run the shared catalog of tracks: performance of the service and our legitimate interest in letting riders reuse tracks others have mapped (Art. 6(1)(b) and (f)).
• Keep the app working, secure and improve it, through anonymous usage statistics: our legitimate interest (Art. 6(1)(f)).
• Invite you to the beta through Apple's TestFlight and contact you about the test: your consent, given by ticking the box in the form (Art. 6(1)(a)). You can withdraw it at any time by writing to us, and we will delete your details.
• Comply with legal obligations and defend our rights: legal obligation and legitimate interest (Art. 6(1)(c) and (f)).

4. Whether you have to give us the data

Location is needed to record sessions: without it, the app can't time your laps, but you can still open it and see your past data. The beta form is optional, but without an email we can't invite you. You are never required to give us your name, email or phone number to use the app, which never asks for them.

5. Who receives your data

We don't sell your data, we don't use advertising identifiers, we don't show ads and we don't track you across other apps and websites.

• Google (Firebase / Google Cloud), our processor, which stores and processes the data described above and hosts this website.
• Apple, for purchases (payments are handled entirely by Apple: we never see your payment details) and, if you join the beta, to send you the TestFlight invitation (your email).
• Other riders, only for the tracks you map (see section 2).
• Authorities, where the law requires it.

6. Transfers outside the European Economic Area

Google may process data in countries outside the European Economic Area. When it does, the transfer relies on safeguards recognised by the GDPR, such as the European Commission's Standard Contractual Clauses or the EU-US Data Privacy Framework.

7. How long we keep it

• Sessions, library and tracks: while you use the app, and then for 12 months.
• Beta tester details: until the end of the beta test, and deleted within 90 days after that, or earlier if you withdraw your consent.
• Anonymous usage statistics: in aggregate form, for as long as they are useful. They can't be linked to you.
• Server logs: for the short period needed for security.

8. Security

Data travels over encrypted connections and is stored in Google's data centres, with access rules that let each rider reach only their own data. No system is perfectly secure, but we take reasonable technical and organisational measures to protect your data.

9. Your rights

Under the GDPR you have the right to access your data, have it corrected or deleted, restrict its processing, receive a copy in a portable format, object to processing based on our legitimate interest and withdraw your consent at any time (for location, switch it off in iOS Settings; this doesn't affect what was processed before). To use these rights, write to info@apexlaps.app. We reply within one month.

Apex has no named accounts, so we may ask you for details, such as tracks and dates of your sessions, to find your data. Anonymous usage statistics can't be traced back to you, so they can't be looked up or deleted one by one. Tracks you mapped may stay in the shared catalog after we remove the link to you.

We don't make decisions about you by automated means, including profiling, that have legal or similarly significant effects.

10. Complaints

If you think we are processing your data unlawfully, please write to us first so we can fix it. You also have the right to lodge a complaint with a supervisory authority, in particular in the country where you live or work. In Italy it is the Garante per la protezione dei dati personali (www.garanteprivacy.it).

11. Children

Apex is not directed at children, and we don't knowingly collect their data. Where the law requires a parent's or guardian's consent for a child to use an online service, that consent is needed. If you think a child has used the app without it, write to us and we will delete the data.

12. Changes

If this policy changes in a way that matters, we will update the date above and, where required, tell you in the app.