Privacy Policy
Effective: 16 February 2025
Last updated: 17 February 2026
Introduction
SteelRep (“we”, “us”, “our”) is operated by ThoughtGears Ltd, a company registered in England and Wales. This Privacy Policy explains how we collect, use, and protect your personal data when you use the SteelRep mobile application.
We are committed to protecting your privacy and handling your data in an open and transparent manner. This policy complies with the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and the California Consumer Privacy Act (CCPA).
Data Controller
ThoughtGears Ltd is the data controller for your personal data.
Contact: privacy@steelrep.app
Data We Collect
Account Data
- Email address (if you create an account)
- Display name (optional)
- Authentication provider (Apple, Google, or email)
Workout Data
- Exercise logs (sets, reps, weight)
- Workout history
- Personal records
- Custom exercises
- Program selections and progress
Device Data
- Device type and operating system
- App version
- Crash reports (via Firebase Crashlytics)
Crash Reports
We collect crash reports by default to maintain app stability. Crash reports include stack traces, device model, and OS version. They do not contain personal workout data or personally identifiable information.
Legal basis: Legitimate interest (GDPR Art. 6(1)(f)) in maintaining a stable, functional service.
Analytics Data
We collect anonymous usage analytics by default to understand which features are most valuable and improve the app experience. This includes app usage patterns (screens visited, features used) and aggregated workout statistics. No personal workout details (exercises, weights, reps) are included.
Legal basis: Legitimate interest (GDPR Art. 6(1)(f)) in improving our service.
Opting Out of Crash Reports and Analytics
You can disable crash reports and/or analytics at any time in the app under Settings → Data & Privacy. Changes take effect immediately.
How We Use Your Data
We use your data to:
- Provide the SteelRep service and features
- Sync your workout data across devices
- Calculate progression and personal records
- Improve the app based on usage patterns
- Send important service notifications
- Respond to support requests
Legal Basis for Processing
Under UK and EU GDPR, we process your data based on:
- Contract performance: To provide the SteelRep service you requested
- Legitimate interests: To improve our service, maintain app stability (crash reports and analytics), and prevent fraud
Data Retention
- Account data: Retained until you delete your account
- Workout data: Retained until you delete your account
- Analytics data: Aggregated data retained for 26 months
- Crash reports: Retained for 90 days
Data Sharing
We share your data only with:
- Firebase (Google): Cloud hosting, authentication, analytics
- RevenueCat: Subscription management
- Apple/Google: App Store and payment processing
We do not sell your personal data.
Your Rights
Under UK GDPR, EU GDPR, and CCPA, you have the right to:
- Access: Request a copy of your data
- Rectification: Correct inaccurate data
- Erasure: Delete your account and data
- Portability: Export your data in a machine-readable format
- Restriction: Limit how we process your data
- Objection: Object to certain processing activities
- Withdraw consent: Opt out of analytics at any time
To exercise these rights, contact privacy@steelrep.app or use the in-app settings.
Data Security
We implement appropriate technical and organizational measures to protect your data, including:
- Encryption in transit (TLS/HTTPS)
- Encryption at rest (Firebase)
- Access controls and authentication
- Regular security reviews
International Transfers
Your data may be transferred to and processed in countries outside the UK/EEA. We ensure appropriate safeguards are in place, including Standard Contractual Clauses with our processors.
Children’s Privacy
SteelRep is not intended for users under 16 years of age. We do not knowingly collect data from children under 16.
Changes to This Policy
We may update this policy from time to time. We will notify you of significant changes via the app or email.
Contact Us
For privacy-related questions or to exercise your rights:
Email: privacy@steelrep.app
Data Protection: ThoughtGears Ltd, United Kingdom
Complaints
If you’re not satisfied with our response, you can lodge a complaint with:
UK: Information Commissioner’s Office (ICO) at ico.org.uk
EU: Your local data protection authority