Swirv Privacy Policy

Welcome to Swirv. We build tools to help cyclists train smarter, plan workouts, and control their indoor trainers. Your privacy is important to us. This Privacy Policy explains what information we collect, how we use it, and the choices you have.

By using the Swirv app, website, or related services ("Services"), you agree to the practices outlined in this Privacy Policy.

If you have any questions, contact us at: legal@swirv.cc

1. Who We Are

Swirv ("we," "us," or "our") is a U.S.-based company that provides an indoor cycling training app including adaptive training plans, workout execution, activity history analysis, and integrations with third-party platforms such as Strava and HealthKit.

We act as the data controller for personal information we process in connection with your use of the Services.

2. Information We Collect

We collect information in three ways:

2.1 Information you provide to us

This includes:

• Account information – name, email address, password (hashed), profile details.
• Training preferences – available training days, goals, discipline preferences, events you add, and settings.
• Feedback and support messages – any information you send to us via email or in-app messages.

We do not collect payment information directly. Payments are handled securely through the Apple App Store.

2.2 Information we collect automatically

When you use Swirv, we collect:

• Device information – OS version, device type, app version.
• Log data – IP address, time of access, diagnostic logs, crash logs.
• Usage data – interactions with features (e.g., workouts started, settings changed) to improve the app.

We do not use third-party advertising SDKs.
Analytics is limited, privacy-respectful, and used only to improve product quality.

2.3 Information from third-party services

If you connect your account to third-party platforms, we may receive:

Strava

When you authorize Strava, we may receive:

• Activity summaries and detailed activity files
• Power, heart rate, cadence data
• Activity metadata (distance, duration, elevation, GPS route if included)

We only access read permissions you explicitly approve.
We upload activities only when you authorize it.

Apple Health / HealthKit

With your permission, we may read:

• Cycling distance
• Heart rate
• Power data
• Calories, workout duration, and activity samples

We do not use HealthKit data for advertising or sharing with third parties.
Health data stays on device unless you explicitly choose to sync it.

Indoor Trainers and Sensors (Bluetooth)

To execute ERG-mode workouts, we read:

• Power
• Cadence
• Speed (if provided)
• Resistance control capabilities

This information is processed in real time and is not shared with third parties.

3. How We Use Your Information

We use personal information for:

3.1 Providing and improving the Services

• Execute structured workouts
• Create adaptive training plans
• Analyze completed workouts
• Maintain your training history and progress metrics

3.2 Personalization

• Adjust workouts based on your fitness level, feedback, and training schedule
• Recommend workouts or training blocks
• Provide insights like intensity, load, and trends

3.3 Communications

• Account updates, service notices, and onboarding guidance
• Customer support
• Messages related to your membership status

We do not send marketing emails without explicit consent.

3.4 Legal and security

• Prevent fraud and misuse
• Comply with legal obligations
• Enforce our Terms of Service

4. How We Share Information

We do not sell your personal data.
We share information only when necessary to provide the Services.

4.1 Service Providers

We may share minimal information with:

• Cloud hosting providers (e.g., Cloudflare)
• Error/diagnostic tools
• Email delivery services

All vendors are contractually required to follow privacy safeguards.

4.2 Third-party integrations

We share data only when you authorize it, such as:

• Uploading completed workouts to Strava
• Exporting or sharing data you choose

4.3 Legal requirements

We may disclose information if required by court order or to prevent harm.

5. How We Store and Protect Your Information

Security

We implement industry-standard technical and organizational measures, including:

• Encrypted network communication (TLS)
• Hashed passwords
• Access controls and audit logging
• Data minimization (we store only what we need)

Data retention

We retain information:

• As long as your account is active
• Or as long as needed to operate the Services

You may delete your account and training data at any time (see Section 9).

6. Children's Privacy

Swirv is not intended for children under 16.
We do not knowingly collect data from children under 16.
If you believe a child has created an account, contact us at legal@swirv.cc.

7. International Data Transfers

Your information may be processed in the United States.
Where required, we rely on legally recognized transfer mechanisms such as Standard Contractual Clauses.

8. Your Rights

Depending on where you live, you may have rights such as:

• Access – request a copy of your data
• Correction – request updates to inaccurate information
• Deletion – request account and data deletion
• Portability – export structured activity data
• Withdraw consent – disconnect integrations (Strava, HealthKit, etc.)
• Opt out of analytics (limited analytics only)

Contact legal@swirv.cc to exercise these rights.

9. Account Deletion

You may request deletion of your account and associated data by:

• Using the in-app delete feature (if available), or
• Emailing legal@swirv.cc

Deletion removes personal data from our systems except:

• Information required for legal or tax obligations
• Previously anonymized analytics

10. Third-Party Links

Our website or app may link to third-party sites.
We are not responsible for their privacy practices.
Please review their privacy policies.

11. Changes to This Policy

We may update this Privacy Policy occasionally.
If changes are material, we will notify you in the app or via email.
Continued use of the Services after changes indicates acceptance.

12. Contact Us

For privacy questions, requests, or concerns:
Email: legal@swirv.cc