Privacy Policy

Application: Trks Document version: 1.0 Effective date: 13 July 2026

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1. Data Controller

This privacy policy applies to the Trks mobile application (hereinafter "the Application"), published by:

• Apptitude SA
• EPFL Innovation Park, Building D, 2ⁿᵈ floor
• 1015 Lausanne, Switzerland
• Phone: +41 21 552 11 70
• Contact for any data protection inquiry: dev@apptitude.ch

2. Applicable Legal Framework

The processing of personal data carried out within the Application is subject to:

• the Swiss Federal Act on Data Protection (revFADP) of 25 September 2020, in force since 1 September 2023;
• the General Data Protection Regulation (GDPR, EU 2016/679) for users residing in the European Economic Area;
• the UK GDPR and the Data Protection Act 2018 for users residing in the United Kingdom.

Any dispute will be governed by Swiss law and submitted to the exclusive jurisdiction of the courts of Lausanne, subject to mandatory consumer protection provisions.

3. Personal Data Collected

The Application collects and processes the following categories of data:

3.1 Account data

• Email address (via Supabase authentication, Google Sign-In or Sign in with Apple)
• Unique user identifier (UUID)
• Account creation date

3.2 Geolocation data

When the user starts a recording, the Application collects the following data in the background at regular intervals throughout the duration of the race:

• Latitude and longitude
• Speed, heading, altitude
• GPS accuracy
• Timestamp and elapsed time since race start

Background collection requires explicit user permission via the operating system (iOS / Android).

3.3 Boat and crew data

• Boat name, boat type
• Bow number, sail number
• Team name
• Registrator email address (when provided)

4. Purposes of Processing and Legal Bases

5. Sharing of Data with Race Organisers

When the user records a race associated with a regatta, the following data is made available to the race organiser through a dedicated dashboard:

• GPS tracks (latitude, longitude, speed, heading, altitude, timestamp)
• Boat name, sail number, bow number, boat type
• Team name
• Registrator email address

The email address of the user account is not shared with organisers.

6. Subprocessors and Recipients

To provide the service, Apptitude SA relies on the following subprocessors, who act under data processing agreements compliant with the GDPR:

No data is sold or transferred to third parties for commercial or advertising purposes.

7. Data Retention

• Recording data (recordings and GPS points): retained without time limit as long as the user's account is active, allowing the user to review past races.
• User account: retained until the user requests deletion.
• Upon account deletion, all associated personal data is erased within a reasonable timeframe, subject to legal retention obligations.

8. User Rights

In accordance with the revFADP and the GDPR, you have the following rights regarding your personal data:

• right of access to your data;
• right to rectification of inaccurate data;
• right to erasure ("right to be forgotten");
• right to restriction of processing;
• right to data portability;
• right to object to processing based on legitimate interest;
• right to lodge a complaint with a supervisory authority: FDPIC in Switzerland, CNIL in France, ICO in the United Kingdom, or any other competent authority in your country of residence within the EEA.

How to exercise your rights

• Account deletion: directly from the Application, via the "Account" page.
• Other rights (access, rectification, portability, objection, restriction): by email to dev@apptitude.ch. A reply will be provided within a maximum of 30 days.

Consent ledger

When you create your account, you are asked to explicitly accept this privacy policy and the terms of service. That acceptance is timestamped and linked to your account (user_consents table) so we can demonstrate compliance with GDPR article 7 (accountability). The ledger stores only your user identifier, the version of the document accepted and the acceptance date.

9. Security

Apptitude SA implements appropriate technical and organisational measures to protect your data against unauthorised access, alteration, disclosure or destruction: encryption of communications (HTTPS/TLS), secure authentication, role-based access controls (Row Level Security), hosting with certified providers.

10. Cookies and Trackers

As a native mobile application, the Application does not use cookies within the meaning of the law applicable to websites. It contains no advertising trackers nor third-party behavioural analytics tools (no Google Analytics, Firebase Analytics, Facebook SDK, etc.).

11. Minors

The Application is intended for users aged 16 years or older. Users under the age of 16 may use the Application only with the prior and verifiable consent of their parents or legal guardians. Any data collected about a minor without the required consent will be deleted upon request.

12. International Transfers

Account, recording and geolocation data is hosted in Switzerland (Zurich) with our subprocessor Supabase. Switzerland benefits from an adequacy decision of the European Commission: EU/EEA to Switzerland data transfers are deemed to provide a level of protection equivalent to the GDPR. For users residing in the United Kingdom, Switzerland is also on the list of adequate jurisdictions recognised by the UK Secretary of State.

Where some subprocessors (Google, Apple, PowerSync, Mailgun) may process data in the United States, such transfers are governed by the European Commission's Standard Contractual Clauses and, where applicable, the Data Privacy Framework (EU-US and UK Extension).

13. Changes to this Policy

This policy may be updated. Any significant changes will be notified to users through the Application or by email. The effective date shown at the top of this document indicates the version in force.

14. Contact

For any question relating to this policy or to the processing of your personal data:

• Email: dev@apptitude.ch
• Mail: Apptitude SA — EPFL Innovation Park, Building D, 2ⁿᵈ floor, 1015 Lausanne, Switzerland

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