Privacy Policy

1. Introduction

This Privacy Policy describes how Floroiu Ionela ("we," "us," or "our") handles information in connection with the Runlock mobile application ("the App").

We are committed to protecting your privacy. Runlock is designed with a privacy-first approach—we collect minimal data, store your personal information locally on your device, and never sell your data.

This Privacy Policy applies to all users of Runlock. By using the App, you agree to the practices described in this policy.

2. Information We Collect

2.1 Personal Information

We do NOT collect personal information.

Runlock does not require you to create an account. We do not collect or store:

• Your name
• Your email address
• Your phone number
• Your physical address
• Any other personally identifiable information

2.2 Anonymous Identifiers

For subscription management, we use RevenueCat, a third-party service. RevenueCat assigns an anonymous identifier to your device to verify your subscription status. This identifier:

• Is generated automatically by your device
• Is not linked to your personal identity
• Cannot be used to identify you as an individual
• Is used solely to determine whether you have an active subscription

2.3 Aggregate Data

We collect only aggregate, anonymous data across ALL users:

Important: This aggregate data:

• Is NOT tied to individual users
• Cannot identify you personally
• Represents totals across the entire Runlock user base
• Is stored on our servers for analytics purposes only

2.4 On-Device Only Data

The following data is stored locally on your device only and is never transmitted to our servers:

3. Information We Do NOT Collect

To be completely clear, Runlock does NOT collect, store, or transmit:

• ❌ Personal health data — Your individual exercise stats stay on your device
• ❌ GPS/Location data — Location is used for run tracking but never leaves your device
• ❌ Camera footage — Push-up and squat detection happens on-device; no images or video are stored or transmitted
• ❌ Screen Time data — Your app usage and blocked app information stays on your device
• ❌ User accounts — We don't have accounts, so we don't store login credentials
• ❌ Email addresses or phone numbers — We never ask for these
• ❌ Individual exercise data — Only aggregate totals across all users are collected
• ❌ Browsing history or app usage patterns — We don't track what you do outside of Runlock

4. How We Use Information

4.1 Subscription Management

We use RevenueCat to process subscriptions through Apple's App Store:

• RevenueCat receives an anonymous device identifier to verify subscription status
• Payment processing is handled entirely by Apple—we never see your payment information
• This allows us to unlock Runlock+ features for active subscribers

4.2 Aggregate Analytics

We collect aggregate exercise totals to:

• Understand overall usage of the App
• Track the collective impact of Runlock users (e.g., "Runlock users have run X million miles together")
• Improve the App and prioritize new features
• Generate anonymous statistics about app usage

These analytics never identify individual users.

4.3 On-Device Processing

• Location Services: GPS is used to track running distance in real-time. All location data is processed on your device and discarded after your run is complete.
• Camera: Your device's camera is used with Apple Vision to detect and count push-ups and squats. All processing happens on-device. No images or video are ever saved, stored, or transmitted.
• Family Controls: Screen Time data is used to block apps you select. This data is managed by iOS and never leaves your device.

5. Third-Party Services

5.1 RevenueCat

Purpose: Subscription and payment management

Data Shared:

• Anonymous device identifier
• Subscription status and transaction information (processed through Apple)

Data NOT Shared:

• Personal information
• Exercise data
• Location data

Privacy Policy: https://www.revenuecat.com/privacy

5.2 Apple App Store

Purpose: Payment processing for subscriptions

All payments for Runlock+ are processed by Apple through the App Store. We do not have access to your payment information (credit card, Apple Pay details, etc.). Apple's privacy practices apply to payment processing.

Privacy Policy: https://www.apple.com/legal/privacy

5.3 Apple Location Services

Purpose: Running/walking distance tracking

• Runlock requests access to your device's GPS to track running distance
• Location data is processed entirely on your device
• Location data is NOT transmitted to our servers or any third party
• You can revoke location access at any time in your device settings

5.4 Apple Vision (On-Device)

Purpose: Push-up and squat detection

• Runlock uses your device's camera with Apple Vision to detect and count exercises
• All processing happens locally on your device using Apple's on-device machine learning
• No images or video are captured, stored, or transmitted
• Camera access can be revoked at any time in your device settings

5.5 Apple Family Controls / Screen Time API

Purpose: App blocking functionality

• Runlock uses Apple's Family Controls to restrict access to selected apps
• All Screen Time data is managed by iOS and processed on your device
• We do not have access to your Screen Time reports or usage data
• This feature is required for Runlock's core functionality

6. Data Storage & Security

6.1 Local Storage

All personal data—including your exercise history, coins, achievements, streak, profile picture, and blocked app selections—is stored locally on your device using iOS secure storage mechanisms.

This means:

• Your data never leaves your device
• Your data is protected by your device's security (passcode, Face ID, Touch ID)
• Your data is automatically encrypted by iOS
• Uninstalling Runlock removes all locally stored data

6.2 Server-Side Storage

The only data stored on our servers is aggregate, anonymous statistics:

• Total distance ran by all users combined
• Total push-ups completed by all users combined
• Total squats completed by all users combined

This data cannot identify individual users and is stored securely with industry-standard protections.

6.3 Data Retention

6.4 Security Measures

We implement appropriate technical and organizational measures to protect data:

• All server communications use HTTPS encryption
• Aggregate data is stored with access controls
• We do not store sensitive personal information

7. Children's Privacy

7.1 Age Requirement

Runlock is intended for users aged 16 years and older. We do not knowingly collect information from children under 16.

7.2 Parental Notice

If you are a parent or guardian and believe your child under 16 has used the App, please contact us at contact@runlock.app. Since we do not collect personal information, there is no data to delete, but we can assist with any concerns.

7.3 COPPA Compliance (United States)

The Children's Online Privacy Protection Act (COPPA) requires parental consent for online services directed at children under 13. Runlock:

• Is not directed at children under 13
• Does not collect personal information from any users
• Does not require account creation

8. Your Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have certain rights under the General Data Protection Regulation (GDPR).

8.1 Legal Basis for Processing

8.2 Your Rights

Under GDPR, you have the right to:

8.3 Data Controller

The data controller for your information is:

Floroiu Ionela
Romania
Email: contact@runlock.app

8.4 Right to Lodge a Complaint

If you believe your privacy rights have been violated, you have the right to lodge a complaint with your local data protection authority. In Romania, this is the National Supervisory Authority for Personal Data Processing (ANSPDCP).

9. California Privacy Rights (CCPA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA).

9.1 Information We Collect

As detailed in this Privacy Policy, Runlock collects:

• Anonymous device identifiers (via RevenueCat) for subscription management
• Aggregate, anonymous exercise totals across all users

We do NOT collect personal information as defined by the CCPA.

9.2 Your CCPA Rights

9.3 We Do Not Sell Personal Information

Runlock does NOT sell, rent, or share your personal information with third parties for monetary or other valuable consideration.

9.4 Contact for CCPA Requests

To exercise your CCPA rights, contact us at: contact@runlock.app

10. International Data Transfers

10.1 Where Data is Processed

• Local data: Processed and stored entirely on your device (no transfer)
• Aggregate analytics: May be processed on servers located internationally
• RevenueCat: Operates servers in the United States and other locations

10.2 Safeguards

When data is transferred internationally, we ensure appropriate safeguards are in place:

• RevenueCat maintains compliance with applicable data protection regulations
• All data transfers use encrypted connections
• We only transfer anonymous, aggregate data that cannot identify individuals

10.3 EU-US Data Transfers

For users in the European Economic Area, any transfer of data to the United States is conducted in compliance with applicable data protection laws, including the use of Standard Contractual Clauses where required.

11. Changes to This Policy

11.1 Right to Update

We may update this Privacy Policy from time to time to reflect changes in our practices, the App, or applicable laws.

11.2 Notification of Changes

When we make changes to this Privacy Policy:

• We will update the "Last Updated" date at the top of this document
• For material changes, we may notify you through the App or via a push notification
• The updated policy will be available within the App

11.3 Your Continued Use

Your continued use of Runlock after any changes to this Privacy Policy constitutes your acceptance of the updated policy. We encourage you to periodically review this policy to stay informed.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: contact@runlock.app

Data Controller:
Floroiu Ionela
Romania

We aim to respond to all privacy-related inquiries within 7 business days.