This policy covers the Toerdle app and the website toerdle.app. It tells you which data we process, what for, who sees it, how long we keep it and what rights you have.
Summary
- Account: You use Toerdle with an account. You sign in with Apple or with Google.
- On your device: Your diary, calorie plan, date of birth, height and sex stay on your iPhone and, while iCloud sync is on, in your private iCloud. The app never sends your date of birth, height or sex to our server, and values from your diary and plan only with your consent.
- Sharing only with consent: The app uploads health and fitness values such as weight, calories, workouts with heart rate and route, or steps only if you explicitly agree. You can withdraw at any time in Settings.
- Who sees what: With your consent, your friends see your daily values and your feed, and every signed-in Toerdle user sees your display name, your profile photo and your leaderboard values. There is no private mode.
- Without consent: Diary, plan and workouts keep working. Friends, challenges and leaderboards stay locked.
- Server: Our server runs at Supabase; the database is in Ireland.
- No advertising: We do not sell your data, show no ads and build no third-party tracking or analytics SDKs into the app. We collect our own crash reports and our own usage statistics with a random installation ID (section 15).
- Minimum age: 16 years.
- Your rights: Access, rectification, erasure (delete your account right in the app), restriction, data portability, objection, withdrawal of consent and a complaint to a supervisory authority.
1. Controller and contact
The controller responsible for data processing is:
Nils Vogel
Posenerstraße 3
35510 Butzbach
Germany
Email: support@toerdle.app
More details are in the Imprint. "We" and "us" in this policy mean the provider. For privacy questions and to exercise your rights, write to the email address above.
2. Scope
This policy covers:
- the Toerdle app for iPhone, with the Apple Watch app, widgets and shortcuts
- the website toerdle.app, including the invitation pages
Additional notes for Austria, Switzerland and the USA are in sections 29 to 31. If you live in the US state of Washington, our Consumer Health Data Privacy Policy also applies.
3. What stays on your device
The app processes a lot of data only on your iPhone and your Apple Watch:
- what you enter during onboarding: name, the email address from sign-in, date of birth, sex, height, weight, goal weight and your goal (e.g. lose weight)
- your calorie plan; the app calculates it on the device
- your food diary: meals, amounts, calories, nutrients, water, weight, notes and supplements
- fasting, your workout history with heart rate, and recorded routes
- your settings
The app stores this data locally on your device by default. We have no access to it. Sections 4 to 18 describe what of it goes to our server or to others. While iCloud sync is on, your device also mirrors your plan and your diary to your private iCloud (section 10).
iPhone and Apple Watch exchange workout plans, running workouts and results directly with each other. The Watch app and the widgets do not connect to the internet themselves. The widgets read their values (e.g. calories, water, steps, the score of a challenge with a friend's name) from shared storage on your iPhone.
Under Settings → Account and data → Privacy → "Delete all my data" you remove the data on this device. Deleting the app removes it too.
4. Your account
You need an account for Toerdle. You sign in with "Sign in with Apple" or with Google. There is no separate Toerdle password.
- With Apple: Apple sends us an identifier, your name and your email address. If you choose "Hide My Email", we only receive a relay address from Apple.
- With Google: You sign in on Google's sign-in page. Google sends us an identifier, your email address and the profile details of your Google account, such as your name and the link to your profile picture.
We store your account (identifier, email address, sign-in provider, with Google also the profile details it sends, and technical sign-in data such as sign-in times) at Supabase. Your sign-in session is kept in your iPhone's Keychain.
- Purpose: account, linking your purchases, social features
- Legal basis: Art. 6(1)(b) GDPR (contract)
- Retention: until you delete your account (section 22)
Apple and Google process data during sign-in as independent controllers. Their privacy policies apply: apple.com/legal/privacy and policies.google.com/privacy.
5. Minimum age
Toerdle is for people aged 16 and over. Before you sign in, the app asks for your date of birth. If you are younger than 16, you cannot go further. So that a second try with a different date does not help, the app remembers the date you entered in this iPhone's Keychain; the entry stays on this device, even after a reinstall, and lifts the block by itself on your 16th birthday.
From iOS 26, the app also asks for your age range through Apple's "Declared Age Range" interface if you share it in your Apple Account. The app evaluates the answer only on the device and does not store it.
Your date of birth stays on your device and, while iCloud sync is on, in your private iCloud. It does not go to our server. The app uses it for the age check and for your calorie plan.
- Legal basis: Art. 6(1)(b) GDPR (minimum age as part of the Terms of Use) and Art. 6(1)(f) GDPR (our legitimate interest in protecting minors)
- Retention: date of birth in your plan until you delete it; the block in the Keychain until the day the blocked date of birth turns 16; Apple's age range is not stored
6. Your consent to sharing health data
Before the app sends health and fitness values to our server, it asks you in a separate step, apart from the Terms of Use and this policy. The step shows you what your friends see and what appears on the "Everyone" leaderboards (section 7). You consent with two checkboxes: that Toerdle stores the values on our server, and that Toerdle shows them to your friends and to all signed-in Toerdle users.
What the consent covers:
- body and nutrition values: weight, goal weight, weight history, your goal, calories, nutrients, water and logged meals
- workouts: duration, distance, calories, heart rate, VO2 max and other measurements, strength exercises with sets, reps and weights, GPS route and workout photos with location
- activity values from Apple Health and from the app: steps, distance, workout time, level, streaks and results of challenges and live duels
This is health data within the meaning of Art. 9 GDPR and sensitive personal data under Swiss law.
- Legal basis: Art. 9(2)(a) and Art. 6(1)(a) GDPR (explicit consent)
The app keeps your decision (yes or no, version of the step, time and language) on your device as a record and reports it to our server. If we extend what is shared, with whom or what for, we ask you again.
If you choose no: You keep using Toerdle as a diary, planner and workout app. Friends, challenges and leaderboards are locked; you can turn them on later. The app then uploads no health or fitness values and no workout photos. Anything it had queued for upload, it discards.
Withdrawal: You can withdraw your consent at any time: Settings → Account and data → Privacy → "Share health data". The app then stops sharing at once and asks our server to remove your shared values: daily values for friends, feed entries with workout photos, leaderboard values and results from challenges and duels. Without an internet connection, the request goes out as soon as you are back online. Friends, challenges and leaderboards are locked afterwards. The withdrawal applies to the future; what happened until then remains lawful. We cannot recall what others have already seen and saved, for example as a screenshot.
No private mode: As long as you have consented, section 7 applies in full. You cannot hide individual values; you can only withdraw your consent as a whole.
You can only consent if you are at least 16 years old (section 5).
7. Who sees what
Every signed-in Toerdle user sees, if you have consented (section 6), your display name and, if you upload one, your profile photo. Without consent you are on no leaderboard and cannot upload a profile photo; your display name is then seen only by people you are already friends with.
If you have consented, every signed-in user also sees:
- your avatar (character, ring, outfit), your level and your experience points (XP)
- your values on the "Everyone" leaderboards: per day steps, distance, workout time and number of workouts, plus your streak in weeks and your duels, each with whether an Apple Watch measured it
- your results on the challenge leaderboards (e.g. push-ups, pull-ups, boxing), including all-time bests
Calories and weight never appear on a leaderboard. Any signed-in user can send you a friend request from a leaderboard.
Your friends also see, with your consent:
- your daily summary: calories eaten, protein, carbohydrates, fat and water with your goals, whether you logged today, your goal, current weight, goal weight, weight trend and weight history of the last 30 days, your recent workouts, your weekly training plan and your streak
- your feed: logged meals with foods, amounts and nutrients; finished workouts with title, duration, distance, calories, splits, heart rate (average, maximum, curve, zones), heart rate recovery, VO2 max and other measurements, device and GPS route including start and end point; for strength workouts the exercises with sets, reps and weights; new personal bests, fasting, streaks, weekly recaps and level-ups
- your workout photos with time taken, location and position on the route
- nudges, cheers, join requests and shared challenges and duels
You become friends when one of you accepts the other's friend request, when someone uses your friend code, QR code or invitation link, or when someone joins a challenge you created with its code. In the last two cases the friendship starts immediately, without you confirming it. So only give your codes and links to people who may see these values. You can remove or block a friend at any time.
New friends also see your earlier feed entries while they are stored (up to 180 days). Please note: the start and end point of a route can reveal, for example, your home address.
Anyone taking part in a challenge or live duel with you, including a randomly matched opponent in a live duel, sees your profile, your progress, your reps and your results there.
Anyone who gets a code from you sees the recipes and workout plans you share by code (section 14).
Only you see your date of birth, your sex, your height, your diary notes, sleep and resting heart rate from Apple Health, and your email address.
We as the operator have access to the data on our server. Only Toerdle's administrators see crash reports, usage statistics and feedback.
8. Friends, feed, challenges, leaderboards and live duels
For the social features we process on our server:
- your profile: display name (1 to 40 characters), profile photo, avatar, level and XP; the app re-encodes photos before upload, which drops embedded metadata
- friend requests, friend codes and QR codes and the status of your friendships; the app keeps your block list only on your device
- invitation links; you send them yourself through other apps (e.g. messengers) when you share
- your daily summary, per day and friendship
- your feed with meals, workouts, routes and workout photos
- your daily values for the leaderboards
- nudges with optional text, cheers and join requests
- challenges: participants, title, progress, time zone and round results
- live duels: start, intermediate scores and result
Real time: Live duels and the Friends area use private real-time channels of Supabase Realtime. In a live duel, your reps go to your opponent over such a channel during the duel. The camera image and the movement detection stay on your iPhone. While you have the Friends area open, the app learns over your channel that something changed for you or your friends; your friends receive new feed entries, daily summaries and profile changes over the channel of your activities. Supabase keeps these messages only briefly for delivery.
Protection against guessed codes: So that nobody can try out friend or challenge codes, our server records every code attempt with your account and time and blocks further attempts when there are too many. Friend codes expire after 14 days and are renewed after each use.
Your friends get notifications, for example when you finished a workout or when you nudge them (section 12).
- Purpose: friends, feed, challenges, leaderboards and live duels; protecting codes against misuse
- Legal basis: Art. 6(1)(b) GDPR for account, profile, friendships and running the features; Art. 9(2)(a) and Art. 6(1)(a) GDPR for health, fitness and location data (section 6); Art. 6(1)(f) GDPR for protection against guessed codes (our legitimate interest in a secure service)
- Retention: section 21
9. Apple Health and Apple Watch
If you allow it in iOS, the app reads from Apple Health: steps, active energy, walking and running distance, weight, height, heart rate, resting heart rate, sleep, activity rings, workouts with routes, stride length, ground contact time, running power, cycling cadence and power, heart rate recovery and VO2 max. The app writes your weight to Apple Health.
The Apple Watch app reads and writes workouts, routes, heart rate, active energy and distances (walking and running, cycling, swimming) and reads cycling cadence.
- Purpose: diary and overview, weight history, training zones and workout details; with your consent also friends, feed and leaderboards
- Legal basis: your consent for upload and sharing (section 6); on the device see section 3
Values from Apple Health leave your device only with your consent under section 6 and only as section 7 describes. Weights from Apple Health stay in a separate file on your device and are not part of the iCloud copy (section 10).
We do not use data from Apple Health for advertising or marketing or for data mining. We do not sell it and do not pass it to third parties without your consent.
You can change at any time which values Toerdle may read and write in the Health app or in iOS Settings. What Toerdle wrote to Apple Health stays there, even if you delete the app or your account; you can delete it in the Health app.
10. iCloud sync
If iCloud sync is on and you are signed in to iCloud, the app mirrors its database to your private iCloud database at Apple (CloudKit). This includes your plan with date of birth, sex, height, weight and goal weight, and your diary. Weights from Apple Health are not included; after a reinstall the app reads them from Apple Health again. Weights you enter yourself that are not in Apple Health belong to the diary and are mirrored. Your workout history and recorded routes are not included. This way your plan and diary come back after a reinstall with the same Apple ID.
Sync is on by default. You turn it off under Settings → Account and data → Privacy → "iCloud sync". We have no access to your private iCloud database; Apple stores it for you. When you delete your account, the app also deletes the copy in your iCloud.
- Legal basis: Art. 6(1)(b) GDPR (the feature you use)
- Retention: until you delete the data or your account
Apple's privacy policy applies: apple.com/legal/privacy.
11. Location, camera and other permissions
The app only asks for permissions when a feature needs them. If you decline, only that feature is missing. You can change permissions at any time in iOS Settings.
- Location: During a cardio workout, the app records your route while you use the app, and during the workout also in the background (iOS shows this). The route stays on your device and goes to your feed only with your consent (sections 6 and 7). For the map view, the app loads map tiles from OpenFreeMap (section 17).
- Motion and fitness: The app measures cadence and treadmill distance. These values are part of the workout.
- Camera: for barcodes, nutrition labels, friend QR codes and counting push-ups in a live duel. The app evaluates the images on your iPhone; they are not uploaded.
- Photos: You pick images for your profile photo, meals and workouts. The app uploads profile photos and, with your consent, workout photos; meal photos stay on your device. If you allow access to your library, the app finds photos from the time of a workout and can save images there.
- Microphone and speech recognition: to dictate meals. Speech recognition runs on your iPhone.
- Calendar: The 5K plan adds training sessions to your calendar.
- Contacts: You pick a person you want to invite through the iOS contact picker. The app reads only that contact and uploads no address book.
- Notifications: section 12
12. Notifications
The app schedules reminders for meals, water, streak, weekly recap, fasting and breaks on your iPhone. Nothing goes to our server for this.
Our server sends notifications from others (nudges, cheers, friends' workouts, leaderboard crowns, live duel reminders) through the Apple Push Notification service. A notification about a workout names you and the sport, no measurements. If you start a workout on your Apple Watch while your iPhone is locked, our server starts the workout display (Live Activity) on your iPhone through Apple; for this the app sends the title and the current state of the workout. For these purposes we store your push token, a token for starting Live Activities, the environment and your notification settings.
- Legal basis: Art. 6(1)(b) GDPR
- Retention: until you delete your account; tokens that Apple reports as invalid are deleted at once
You turn notifications off in iOS Settings.
13. Toerdle Pro
You buy Toerdle Pro through the App Store. Apple sells it, bills it and handles the payment. We receive no payment data.
From the app and from the App Store server notifications we receive the signed purchase information: product, status, expiry date, whether the subscription renews, Apple's transaction ID and whether it is a test purchase. It is linked through an identifier that matches your Toerdle account. If you redeem the Pro gift in your profile, we store the start and end of that period.
- Purpose: unlocking Pro on your devices, handling renewals, expiry and refunds
- Legal basis: Art. 6(1)(b) GDPR
- Retention: until you delete your account
Deleting your account does not end your subscription. You cancel it in your Apple Account settings. Apple's terms and privacy policy apply to the purchase.
14. Sharing recipes and plans by code
If you share a recipe or a workout plan by code, we store its content on our server, plus the app version and language. For workout plans we also store your name as the sender and your weights if you include them. Anyone with the code can fetch the content.
- Legal basis: Art. 6(1)(b) GDPR
- Retention: recipes can be fetched for 180 days, plans for 365 days. After that they can no longer be fetched but remain stored. We delete recipes whose code your device knows together with your account. Shared plans carry no link to your account and remain stored after account deletion; we delete them on request.
15. Crash reports and usage statistics
On first launch the app creates a random installation ID and stores it on your device. It contains nothing about you and is deleted when you delete the app, your account or all your data.
Crash reports: If the app crashes or iOS (MetricKit) reports a crash, the app sends a report to our server: time, app version and build, iOS version, device model, installation ID, current screen, error type and text, call stack and the iOS diagnostics. We analyse the reports on a developer machine. An internal Slack channel receives a short note with the error signature, build, number of affected devices and screen.
Usage statistics: Once a day the app sends counters to our server: app launches, onboarding steps, views of the Pro page and purchases and restores made there, logged meals, searches, started and finished workouts, duels, challenges, new friends and the areas of the app you used. Added to this are up to 20 search terms a day that found nothing in the food search, the app version and the installation ID. If you are signed in, we link the row to your account. Through the shared installation ID, crash reports can then also be linked to your account.
We use no third-party analytics or crash services and do not use this data for advertising. Only Toerdle's administrators see it.
- Purpose: finding and fixing bugs, closing gaps in the food database, improving the app
- Legal basis: Art. 6(1)(f) GDPR; our legitimate interest is a stable app and a food search that finds what you look for
- Retention: crash reports until the bug is fixed and the affected app version is no longer in use; usage statistics as long as we need them to compare over time. If you delete your account, we remove the link between the usage statistics and your account.
You can object to this processing under Art. 21 GDPR (section 23); write to support@toerdle.app.
16. Feedback, support and reports
Feedback in the app (Settings → Help & feedback → "Send feedback"): We store your text with app version, build, iOS version, device model, language and region, the current screen and a random ID. The feedback is not linked to your account. To sort feedback, we use the AI model Claude by Anthropic on a developer machine; the text goes to Anthropic in the process. An internal Slack channel receives a short title. Without an internet connection, the app opens a prepared email to us.
Support by email: If you write to us, we process your address and the content of your message.
Reporting people or content: "Report" in the app (on people, leaderboards, challenges, live duels, the feed and photos) sends the report to our server. We store your account ID, the reported person's ID, the reason you chose, your note and the place you reported from, to review the report and take action. We keep it until the report is handled and for as long as we need it to show what we did. Reports without the app reach us by email at support@toerdle.app.
Blocking and word filter: When you block a person, we store your account ID and the blocked person's ID on our server so that neither of you sees the other anywhere (leaderboards, challenges, live duels, feed, profile photo, requests). You can lift the block in Settings. The server checks display names and challenge titles against a list of unacceptable terms when they are saved; we store nothing extra for that.
Beta tests via TestFlight: If you take part in a beta test, we receive through Apple the feedback, screenshots and crash information you send in TestFlight, with your name in TestFlight.
- Purpose: answering your request, reviewing reports, fixing bugs, improving the app
- Legal basis: Art. 6(1)(b) GDPR (your request), Art. 6(1)(f) GDPR (our legitimate interest in a better and safer app), for reports Art. 6(1)(c) GDPR in conjunction with Art. 16 of the Digital Services Act
- Retention: until your matter is settled and no statutory retention duties remain. Feedback in the app is not linked to your account and therefore remains stored after account deletion.
17. Content from other providers
For some features the app connects directly to other providers. They see your IP address, details about the app and device, and the content of the request. They process the data as independent controllers.
- Open Food Facts (France): barcode lookups and online food searches with the search term. Privacy: world.openfoodfacts.org/privacy
- OpenFreeMap (Hungary): map tiles for the route view; the provider sees the map area. Privacy: openfreemap.org/privacy
- Unsplash: recipe images in the meal plan. Privacy: unsplash.com/privacy
- Apple: the App Store check for an update, and map snapshots from Apple Maps when you share a workout as a video
- Legal basis: Art. 6(1)(b) GDPR for features you use (search, map, sharing); Art. 6(1)(f) GDPR for recipe images and the update notice (our legitimate interest in a complete display and an up-to-date app)
18. Website toerdle.app
Hosting: The website is hosted by Vercel Inc. (USA). When you visit, Vercel processes your IP address, date and time, the address requested and details about your browser and device. On invitation pages, the invitation code is part of the address.
- Purpose: delivering the website and protecting it from attacks
- Legal basis: Art. 6(1)(f) GDPR (our legitimate interest in a secure, available website)
Audience measurement: We count page views with Vercel Web Analytics. The script comes from our own domain, sets no cookies and stores nothing on your device. Vercel records the page visited, the referring page, country, device type, operating system and browser; Vercel tells individual visits apart with a value derived from the request that changes daily. We only see aggregated numbers. On invitation pages, the page also counts, without any identifier, how often it was viewed and how often "Open" or the App Store link was tapped.
- Purpose: understanding which pages are read and how invitations land
- Legal basis: Art. 6(1)(f) GDPR (our legitimate interest in a website that reaches its visitors)
No cookies, no advertising: The website sets no cookies and embeds no advertising or tracking services.
Light or dark: If you switch the color scheme, the website stores your choice in your browser's local storage. This is necessary for the feature you explicitly use to work (Section 25(2) No. 2 TDDDG, German Telecommunications Digital Services Data Protection Act).
Links: Links to the App Store, TestFlight or support services lead to other providers. Their privacy policy applies only once you tap them.
19. Recipients and processors
- Supabase (processor): server, database, sign-in, file storage, real-time channels and server-side functions. The contracting party is Supabase Pte. Ltd. (Singapore); Supabase, Inc. (USA) provides support and operations.
- Vercel Inc. (USA, processor): hosting and audience measurement of the website
- Anthropic, PBC (USA): sorting feedback (section 16)
- Slack (USA): internal short notes on crashes and feedback (sections 15 and 16)
- Apple (independent controller): Sign in with Apple, App Store and in-app purchases, push notifications, iCloud, Apple Health, Apple Maps, TestFlight and our email mailboxes
- Google (independent controller): sign-in with Google
- Open Food Facts, OpenFreeMap, Unsplash (independent controllers): section 17
- Other Toerdle users: your friends, all signed-in users and the people you take part in challenges and duels with, as described in section 7
- Authorities: only if we are legally required to
20. Storage locations and transfers to third countries
Toerdle's database, sign-in and file storage are at Supabase in a data center in Ireland (AWS region eu-west-1).
Outside the EU and the EEA, data is processed by:
- Supabase: Supabase, Inc. (USA) and Supabase Pte. Ltd. (Singapore) for operations and support. Server-side functions can run in the Supabase region closest to you; if you use Toerdle outside Europe, this can also be outside the EU.
- Vercel, Anthropic and Slack (USA)
- Apple and Google (including the USA), as independent controllers under their privacy policies
For transfers to the USA we rely on the European Commission's adequacy decision for the EU-U.S. Data Privacy Framework where the recipient is certified under it, otherwise on the European Commission's Standard Contractual Clauses. For Singapore, the Standard Contractual Clauses apply. You can get a copy of the Standard Contractual Clauses on request at support@toerdle.app.
21. Retention
We store data only as long as the purpose requires. In detail:
- Account, profile, profile photo, push tokens, subscription information: until you delete your account. An hourly job deletes replaced profile photos.
- Feed entries with workout photos: 180 days, then a daily job deletes them. Entries you delete are removed for good after 7 days. Photos are deleted with their workout.
- Nudges and join requests: 60 days. Cheers are deleted with the feed entry.
- Daily summaries for friends: until the friendship ends (remove, block, decline) or you delete your account
- Leaderboard values, challenges and duels: until you delete your account
- Friendships: until a friendship ends or you delete your account
- Friend codes: 14 days or until used
- Code attempts: 2 days
- Shared health data after a withdrawal: section 6
- Recipes and plans shared by code: section 14
- Crash reports, usage statistics: section 15
- Feedback, emails and reports: section 16
- Website: Vercel keeps access logs only briefly for operations and security; the audience measurement contains no data that lets us recognise you
- Data on your device and in your iCloud: until you delete it (sections 3 and 10)
22. Deleting your account
You delete your account in the app under Settings → Account and data → "Delete account". Without the app, write to us at support@toerdle.app; more at toerdle.app/en/delete-account.
What we delete: your account, your profile, your profile photo, your workout photos, your friendships, requests and codes, your daily summaries, your feed, your leaderboard values, your progress in challenges and duels, your subscription information, your push tokens, recipes whose code your device knows, and challenges you created that nobody else joined. On your device the app deletes all data including the installation ID, plus the copy in your iCloud, and signs you out.
What remains:
- challenges others are still playing continue for them without a link to you; a title you entered remains
- shared workout plans, possibly with your sender name (section 14)
- crash reports and usage statistics without a link to your account (section 15)
- feedback and emails (section 16)
- what Toerdle wrote to Apple Health (section 9)
- what others have seen of you and saved themselves
You can also disconnect your Apple sign-in in your Apple Account settings under "Sign in with Apple". A running subscription does not end with account deletion. Cancel it in your Apple Account settings.
23. Your rights
Under the GDPR you have the right to:
- access your data and get a copy (Art. 15)
- rectification of incorrect data (Art. 16); you change your display name and profile photo yourself in the app
- erasure (Art. 17); you delete your account yourself in the app (section 22)
- restriction of processing (Art. 18)
- data portability (Art. 20); the app has no export feature, we send you your data on request
- object (Art. 21): You can object at any time to processing based on our legitimate interest (Art. 6(1)(f) GDPR), such as the usage statistics. We then stop processing the data unless we have compelling legitimate grounds.
- withdraw your consents (section 24)
- complain to a supervisory authority (section 25)
Write to us at support@toerdle.app. We answer within one month.
24. Withdrawing consent
You can withdraw consents at any time with effect for the future:
- sharing health data: Settings → Account and data → Privacy → "Share health data" (section 6)
- access to Apple Health, location, camera, microphone, calendar, photos and notifications: in iOS Settings or in the Health app
- iCloud sync: Settings → Account and data → Privacy
25. Right to complain
You can complain to a data protection supervisory authority, in particular in the country where you live or work or where the alleged infringement took place.
The authority responsible for us is the Hessian Commissioner for Data Protection and Freedom of Information (Der Hessische Beauftragte für Datenschutz und Informationsfreiheit), Postfach 3163, 65021 Wiesbaden, Germany, datenschutz.hessen.de.
26. Obligation to provide data
- Account: You cannot use Toerdle without an account.
- Date of birth: Without a date of birth we cannot check the minimum age or calculate a calorie plan.
- Name and email address: Both are voluntary. If you enter a name, it becomes your display name (section 7); without a name, others see you as "Toerdle".
- Everything else is voluntary: You need height, weight and goals for a personal plan. You need Apple Health, location and other permissions only for the respective feature. You need the consent to sharing only for friends, challenges and leaderboards.
27. Automated decisions
From your details, the app calculates a calorie plan and reference values on your device, and the server sorts leaderboards. This has no legal or similarly significant effect on you. We make no automated decisions within the meaning of Art. 22 GDPR.
28. Security
- The app connects to servers only over encrypted connections (HTTPS).
- Your sign-in session is kept in your iPhone's Keychain.
- Access rules in the database make sure others only see what section 7 describes.
- The app re-encodes photos before upload, which drops embedded metadata such as the camera's location. We store the location of workout photos separately (section 7).
- Our server limits code attempts so nobody can guess friend or challenge codes (section 8).
29. Austria
The GDPR and the Austrian Data Protection Act apply to you. You can also complain to the Austrian Data Protection Authority.
30. Switzerland
The Swiss Federal Act on Data Protection (FADP) also applies to you. Health data is sensitive personal data; we ask for your explicit consent before sharing it (section 6).
Recipient countries: Ireland (database), France (Open Food Facts), Hungary (OpenFreeMap), USA (Supabase, Inc., Vercel, Anthropic, Slack, Apple, Google) and Singapore (Supabase Pte. Ltd.). For the USA, the Swiss-U.S. Data Privacy Framework applies where the recipient is certified under it, otherwise Standard Contractual Clauses; for Singapore, Standard Contractual Clauses apply.
We have not designated a representative in Switzerland under Art. 14 FADP; the legal requirements for this are currently not met. You can contact the Federal Data Protection and Information Commissioner (FDPIC).
31. USA
- No sale, no advertising: We do not sell personal data, do not share it for advertising and do not use it for targeted advertising.
- Health data: Toerdle processes consumer health data, for example weight, calories, heart rate and workouts. If you live in Washington, our Consumer Health Data Privacy Policy also applies, with your rights to access, deletion and withdrawal of consent.
- Children: Toerdle is not directed at children. The minimum age is 16 years.
32. Features that are not active
- AI photo analysis of meals: not active; the app sends no photos for analysis.
- Data donation (correction suggestions for foods): not active; the app sends no suggestions.
Before we turn on one of these features, we update this policy and, where needed, ask for your consent.
33. Changes to this policy
We update this policy when the app, our providers or the law change. The version with the date above applies. If a change needs your consent, we ask you first.