Effective date: 2026-10-29

This privacy policy explains how SportApp collects, uses, stores, and otherwise processes users' personal data when they use the SportApp mobile application and the services provided within it.

The personal data controller of SportApp is MB “SVEIKAI”.

This privacy policy is an informational document. When user consent is required for the processing of personal data, it is requested separately.

1. What personal data we collect

Depending on the SportApp features used by the user, we may process the following data:

Account and contact data

• first name and last name;

• email address;

• account identifier;

• login and account security information;

• language selected by the user and other account settings.

Data required for workout plans and recommendations

• age;

• body weight;

• fitness level;

• fitness goal;

• selected sports equipment;

• other information voluntarily provided by the user, necessary to select an appropriate workout plan, individual workout, or recommendation.

Workout and progress data

• completed and scheduled workouts;

• workout calendar and history;

• sets, repetitions, rest, heart rate, or intensity data, if entered by the user;

• body weight and measurement changes;

• burned calories and covered distance data;

• workout statistics;

• progress photos voluntarily uploaded by the user, intended solely for personal progress tracking;

• water consumption data and related recommendations.

Progress photos are not published publicly, are not shown to other SportApp users, and are not used for advertising without the user's separate consent.

SportApp employees and administration do not review progress photos during normal operations. Limited access to them may only be granted to authorized technical specialists when necessary to fulfill a user's request, resolve a technical issue, investigate a security incident, or fulfill a statutory obligation.

Subscription and payment data

• selected subscription plan;

• subscription start, renewal, cancellation, and expiration dates;

• payment amount, currency, and payment status;

• Stripe customer, subscription, and transaction identifiers;

• applied discounts;

• history of payments, refunds, and failed payments.

All payments are processed by Stripe. SportApp does not store full payment card numbers, card verification codes, or other full card authentication data.

Technical and usage data

When using the SportApp application, the following may be collected automatically:

• IP address;

• device type;

• operating system and application version;

• login and usage time;

• system performance and error logs;

• security information.

SportApp does not currently collect precise user location data. If such a feature were to be introduced in the future, the user would be provided with relevant information and, where required, their consent would be requested.

Data necessary for registration, account administration, subscription, and the provision of relevant SportApp features are marked as mandatory. Failure to provide them may make it impossible to create an account, administer a subscription, or provide the corresponding SportApp feature. Optional data is provided by the user voluntarily.

2. Sources of personal data

We obtain personal data:

• directly from the user during registration and use of SportApp;

• automatically from the user's device and SportApp systems;

• from Stripe when processing a payment or managing a subscription;

• from email and customer support systems when the user contacts SportApp;

• from other lawfully used technical service providers when necessary for the operation and security of SportApp, or to fulfill a user request.

3. For what purposes we use the data

We use personal data in order to:

• create and administer the user account;

• provide access to SportApp;

• select workout plans, individual workouts, and recommendations based on the data provided by the user;

• provide the workout calendar, history, statistics, and progress tracking features;

• provide water consumption recommendations and tracking;

• administer subscriptions, payments, discounts, and refunds;

• verify eligibility for a one-time free trial period;

• detect and prevent multiple account creation, fraud, account sharing, and other abuse;

• respond to user inquiries and handle requests or complaints;

• send important notifications related to the account, security, subscription, or service operation;

• with the user's consent, send newsletters, offers, and other marketing information;

• ensure SportApp security, fix bugs, and improve the service;

• fulfill accounting, tax, consumer protection, and other legal obligations;

• establish, exercise, or defend legal claims.

4. Legal bases for data processing

We process personal data based on one or more of the following legal bases:

• performance of a contract, where the data is necessary to create an account, provide SportApp services, select workout plans, manage a subscription, or fulfill a user request;

• the user's consent, where the user voluntarily provides optional progress, body, or other more sensitive data, uploads progress photos, or agrees to receive marketing communications;

• a legal obligation, where we are required to store or provide data under accounting, tax, consumer protection, or other legal acts;

• the legitimate interest of SportApp, where the data is necessary for system security, fraud and abuse prevention, technical operation, customer support, service improvement, or defending legal claims, provided that these interests are not overridden by the user's rights and freedoms.

5. Health and other more sensitive data

Certain data voluntarily provided by the user, such as body weight, measurements, fitness information, injuries, or other health-related conditions, may be considered health data.

Such data is processed only to the extent necessary to provide the SportApp features selected by the user, and based on the user's explicit consent or another legal basis provided by law.

The user is not required to provide optional progress or health data. However, without providing it, certain SportApp recommendations or features may be less tailored to the user.

The user may withdraw their consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

6. Automated selection of workout plans and recommendations

SportApp may automatically use the information provided by the user to select workout plans, individual workouts, and recommendations.

The selection may be made based on criteria such as the user's fitness goal, fitness level, workout location, and selected equipment.

This selection is not used for decisions that would produce legal effects or similarly significantly affect the user.

If the user believes that the selected plan is unsuitable, they may modify their submitted data, choices, or contact SportApp.

7. Free trial period control and abuse prevention

A free trial period is granted to a natural person only once.

In order to determine whether a user has already used the free trial period, SportApp may evaluate account, subscription, and payment system identifiers as well as other reliable technical indicators.

This data is used only to the extent necessary to detect and prevent repeated use of the free period, fraud, and other abuse.

A decision not to grant a repeated free period may be reviewed upon the user contacting by email at info@sportapp.lt.

8. Emails and marketing

SportApp may send the user notifications necessary for providing the service, for example:

• registration and account confirmations;

• password reset messages;

• subscription, payment, and free trial information;

• security notices and notifications of significant service changes;

• responses to user inquiries.

These notifications do not constitute marketing and may be sent to the extent necessary to perform the contract or comply with legal requirements.

News, offers, and promotional messages are sent upon obtaining the user's consent or on another basis permitted by law.

The user may opt out of marketing communications at any time by clicking the unsubscribe link provided in the email or by contacting via email at info@sportapp.lt.

Opting out of marketing does not affect notifications that are necessary for the account, subscription, payment, or system security.

9. To whom data may be transferred

SportApp does not sell users' personal data.

Personal data may be transferred only to the extent necessary to:

• Stripe – to process subscriptions, payments, and refunds;

• email service providers, including Twilio SendGrid – to send service-related notifications and marketing communications chosen by the user;

• server, data storage, and technical infrastructure service providers;

• service providers ensuring application operation, content delivery, and security;

• SportApp developers and maintenance service providers when access is necessary to maintain the system or troubleshoot an issue;

• accounting, legal, auditing, and other professional service providers;

• state authorities, courts, or law enforcement agencies when required by applicable laws;

• another entity in the event of a transfer of business or part thereof, reorganization, or a similar transaction, ensuring adequate data protection.

Service providers are permitted to process data only in accordance with SportApp's instructions, contracts, and applicable data protection requirements, except where the service provider itself acts as an independent data controller.

10. Data transfers outside the European Economic Area

Some SportApp service providers may process data outside the European Union or the European Economic Area.

In such cases, data is transferred only subject to the safeguards provided by law, such as:

• an adequacy decision by the European Commission;

• standard contractual clauses approved by the European Commission;

• other safeguards permitted under the General Data Protection Regulation.

The user may obtain more information about the safeguards applied to a specific data transfer by contacting via email at info@sportapp.lt.

11. How long we store data

We store personal data no longer than necessary for the purposes for which it was collected.

The data retention period is determined taking into account:

• the duration of the account and subscription validity;

• the SportApp features used by the user;

• the user's request to delete the account or withdraw consent;

• statutory retention periods set out in accounting, tax, and other legislation;

• the necessity to prevent fraud and repeated use of the free period;

• statutory limitation periods for bringing or defending potential legal claims;

• technical backup update cycles.

Account, workout, and progress data are generally stored for as long as the user's account is active.

When a user deletes their account, the data associated with the account is deleted or irreversibly anonymized within a technically reasonable period, except for data that we are required to retain further under applicable laws or that is necessary for fraud prevention and the defense of legal claims.

Data may remain in backups until the scheduled replacement of backups, but during this period it is not used for SportApp's ordinary activities.

Payment and accounting documents are retained for the period established by law.

Marketing data is stored until the user withdraws consent or as long as it is necessary for lawful marketing activities and proving consent.

12. User rights

Subject to applicable conditions, the user has the right to:

• obtain information about the processing of their personal data;

• access their personal data processed by SportApp;

• request rectification of inaccurate or completion of incomplete data;

• request erasure of personal data;

• request restriction of data processing;

• object to data processing based on legitimate interest;

• object to direct marketing at any time;

• receive their provided data in a structured, commonly used, and machine-readable format and, where applicable, transmit it to another data controller;

• withdraw consent at any time;

• request human intervention when a decision significantly affecting the user would be made solely by automated means.

To exercise their rights, the user may contact via email at info@sportapp.lt.

Before fulfilling a request, SportApp may ask for information necessary to verify the user's identity.

Requests are responded to without undue delay and generally no later than within one month. In complex cases, the deadline may be extended in accordance with the procedure established by law.

13. Account and data deletion

The user may submit a request to delete their SportApp account using the account deletion feature provided in the application or by contacting via email at info@sportapp.lt.

Account deletion does not automatically eliminate statutory obligations to retain payment, accounting, security, or legal claim data.

Data necessary to determine whether a person has already used the one-time free trial period may be stored in a limited and, where possible, pseudonymized form to the extent necessary for abuse prevention.

14. Data security

SportApp implements reasonable technical and organizational security measures designed to protect personal data from unauthorized access, loss, alteration, disclosure, or destruction.

Access to personal data is granted only to those individuals and service providers who need it to perform their functions.

Although SportApp takes reasonable security measures, no electronic system can guarantee absolute security.

15. Children's privacy

SportApp is intended for individuals aged 16 and older.

SportApp does not knowingly intend to collect data from individuals under 16 years of age without the consent of parents or legal guardians required by law.

If it becomes known that data of an individual under 16 years of age has been collected without an appropriate legal basis, the account may be suspended and the data deleted or otherwise handled in accordance with the procedure established by law.

16. Changes to the privacy policy

SportApp may periodically update this privacy policy due to changes in services, technologies, data processing methods, or legal requirements.

The updated policy will indicate the new effective date.

Users will be informed in an appropriate manner about material changes that may significantly affect user rights or data usage before the changes take effect, where required by law.

17. Contact information and complaints

Personal data controller:

MB “SVEIKAI”
Address: V. Krėvės pr. 104, Kaunas, Lithuania
Email: info@sportapp.lt

If the user believes that their personal data is being processed improperly, they are invited to contact SportApp by email at info@sportapp.lt.

The user also has the right to lodge a complaint with the State Data Protection Inspectorate (https://vdai.lrv.lt) or the competent data protection supervisory authority of another European Union or European Economic Area country where the user resides, works, or where the alleged infringement took place.