Privacy Policy for The PWR App

Last Updated: September 30, 2025

1. Introduction

Welcome to the PWR App. Your privacy is a top priority for us. This Privacy Policy explains how ASVAL ALPHA TECHNOLOGY S.R.L. ("we," "us," or "our") collects, uses, shares, and protects your information when you use our mobile application ("App"), our website at https://www.thepwrapp.com ("Website"), and all related services (collectively, the "Service").

By accessing or using our Service, you agree to the collection and use of information in accordance with this policy.

2. Who is Responsible for Your Data?

The data controller responsible for your personal information is:

ASVAL ALPHA TECHNOLOGY S.R.L.

A company registered in Romania.

Contact Email for Privacy Inquiries: hello@thepwrapp.com

As we do not have a dedicated Data Protection Officer, all inquiries regarding your data and privacy rights should be directed to the administrator at the email address above.

3. What Information We Collect and How

We collect information in several ways, with a core principle of minimizing data collection and maximizing your control.

Types of data collected consists of Product Interaction, Device ID, Other Diagnostic Data, Crash Data, Performance Data, Name, Coarse Location, Email Address, User ID, and Purchase History. The data is being used for app functionality and analytics, as listed below:

a) Information Stored Locally on Your Device (Your Workout Data)

The vast majority of the data you create is stored securely and exclusively on your device. We cannot access, view, or decrypt this data. This includes:

  • Workout names, notes, and schedules;

  • Exercises, sets, reps, weight, and durations;

  • Tracked body weight and exercise notes.

b) Information You Provide to Us Directly

  • Account Information: When you sign up using Google or Apple Sign-In, we collect your Name, Email Address, a unique user ID specific to our app, and optionally, your profile picture from that service. This is the only personal data we store on our servers to manage your account.

  • Communications: When you contact us at hello@thepwrapp.com, we collect your email address and any information you provide in your message to assist you (see section 6.3).

c) Information We Collect Automatically

  • Analytics and Performance Data: We collect anonymized or pseudonymized data to understand how our Service is used, to identify and fix issues, and to improve your experience. This includes tracking user behavior (not individual users), crash reports, and UI interactions. This data is collected via a random user ID that is not tied to your personal account information.

  • Device and Connection Information: We may collect information about your device (e.g., device type, operating system) for crash reporting and service optimization.

  • Cookies and Similar Technologies: Our Website uses cookies for essential functions and analytics. Our App uses minimal tracking technologies for essential functions and to analyze and improve app performance and stability. You will have control over non-essential tracking.

d) Information from Third Parties

  • Payment and Subscription Data: We use Apple, Google, and RevenueCat to process subscriptions. We do not receive or store your credit card information. We receive information from them to confirm your subscription status, such as a transaction ID and subscription tier.

  • Troubleshooting Data: Our application is built using the Expo platform. To help us ensure the app runs as expected and identify potential errors, Expo may collect a small amount of anonymous, technical data from your device. This information does not personally identify you. It is used by the Expo team to troubleshoot technical issues and improve their platform, which helps us provide you with a better experience. For more details, you can review the Expo Privacy Policy.

4. How and Why We Use Your Information (Purpose and Legal Basis)

We only use your data when we have a valid legal reason to do so under General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA).

5. Who We Share Your Information With

We do not sell your personal data. We only share it with trusted third-party service providers who help us operate our Service. The data we collect and share with the following third-party providers is anonymous and not linked to you directly:

  • Authentication Services: Google and Apple, to facilitate secure sign-in.

  • Payment Processors: Apple, Google, and RevenueCat, to securely handle subscriptions.

  • Analytics & Performance Providers: Google (Analytics, Play Console), Apple (App Store Console), Microsoft (Clarity), Sentry.

  • Cloud Hosting Providers: We use servers from Hetzner located in the EU to store your Account Information and future encrypted backups.

  • Website Hosting: Squarespace.

6. Data Retention and Deletion

6.1 Account Information

When you choose to delete your account, your account data on our servers is deleted permanently. You may sign up again with the same email, but your account-level data will be gone.

6.2 Local Workout Data

Your locally stored workout data is encrypted and remains on your device until you uninstall the app or clear the app data. We cannot access, view, or decrypt this data.

6.3 Communications Data

When you contact us for support at hello@thepwrapp.com, we may collect and process the Contact Information you provide (e.g., your email address) and the content of your communication (collectively, "Communications Data").

  • Purpose: We retain this data solely to address your inquiry, provide effective technical assistance, and improve the quality of our service.

  • Marketing Policy: Your Contact Information is not used for marketing purposes unless you have provided us with your explicit consent.

6.4 Account and data deletion

To initiate the deletion process for your App data, including your Workout Data and any Account and linked data, please refer to the Your Account & App Data Deletion instructions.

You have the right to request the deletion of your Communications Data (your email and related content) by sending a request to hello@thepwrapp.com.

Upon receipt of a verified deletion request, we will take all reasonable steps to delete the data associated with your email address; however, complete deletion across all backup systems may take up to ninety (90) days.

7. Security of Your Information

We use administrative, technical, and physical security measures to protect your personal information. This includes:

  • Encryption for all data at rest on our servers as well as full disk encryption.

  • Encryption for all data transferred between the app and our servers.

  • Full filesystem encryption on the virtual private servers that host our databases.

  • Industry-leading encryption for all workout data stored locally on your device.

8. Data Protection and Privacy

8.1 General Data Protection Regulation (GDPR)

If you are a citizen of a European Union member state, you have rights concerning your personal data. We are committed to facilitating them.

  • The Right to Access: You can request a copy of the personal account information we hold about you.

  • The Right to Rectification: Your basic account data (such as name, email, and picture) is sourced from Google/Apple. To correct this information, you must update your details directly with those services and then sign in to our app again. We will then update our records with the rectified information upon your next sign-in. For workout data stored locally on your device, you can edit or correct specific entries directly within the app's workout log or editing features.

  • The Right to Erasure: You have the right to delete your account and associated server data at any time. When you choose to delete your account, your account data on our servers is deleted permanently. To initiate the process of deletion of your account and data, please refer to the Your Account & App Data Deletion instructions. Your workout data (stored locally) will be deleted upon uninstalling the app from your device. Uninstalling will not remove your server-side account data.

  • The Right to Data Portability: Please note that workout data is stored and processed solely on your device. You have the right to access your encrypted backup file to move as you see fit. You can request a copy of your basic account information (as sourced from Google/Apple) by contacting us at hello@thepwrapp.com.

  • The Right to Restrict Processing & The Right to Object: You have the right to object to our processing of your data for our legitimate interests. You will have an option in the app's settings to disable the collection of non-essential analytics data.

  • The Right to Withdraw Consent: Where we rely on your consent (e.g., for marketing emails), you can withdraw it at any time.

8.2 California Consumer Privacy Act (CCPA)

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), such as the right to request information about the categories of data we collect and to request deletion of your personal data.

9. International Data Transfers

Your information, specifically your Account Information, may be transferred to and maintained on computers located outside of your state, province, or country. We use Hetzner servers located in the EU.

We ensure such transfers are protected by appropriate safeguards, primarily through the use of Standard Contractual Clauses (SCCs) as approved by the European Commission, which contractually bind our service providers to protect your data to EU standards.

10. Policy for Children

Our Service is not directed to individuals under the age of 13. We do not knowingly collect personal information from children under 13.

If you are a parent or guardian of a child using the App (aged 13-16 in the EU) and would like more information, you can contact us at hello@thepwrapp.com. To initiate the process account and data deletion on their behalf, please refer to the Account & App Data Deletion instructions.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. We may also provide notice through the App.

12. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at: hello@thepwrapp.com.