Privacy Policy
Last updated: 2026-06-06
This policy explains how Vargr processes your personal data under the EU GDPR (Reg. 2016/679). Draft — to be reviewed by a lawyer before publication.
1. Data controller
The controller is [LEGAL ENTITY / NAME], [ADDRESS], email [EMAIL]. Contact this address for any data matter.
2. Data we collect
Account data (name, email); training and nutrition data; health-related data (weight, measurements, check-ins, Apple Health data) which is special-category data (Art. 9 GDPR); payment data handled by our payment provider; technical usage data.
3. Purposes and legal bases
Service delivery (contract, Art. 6.1.b); health data on the basis of your explicit consent (Art. 9.2.a); payments and tax obligations (Art. 6.1.b and 6.1.c); security and abuse prevention (legitimate interest, Art. 6.1.f).
4. Coaches and marketplace
If you choose a human coach, the data needed for coaching is shared with that coach, who acts as controller for their own activity. Vargr provides the platform and tools.
5. Processors
We use providers that process data on our behalf: Supabase (hosting & database), Stripe (payments), Anthropic (AI features), Apple (in-app purchases and, if you allow it, Apple Health). Data processing agreements are in place with each.
6. Apple Health
If you grant access, we only read the listed data (e.g. weight, steps) to show it in the app. We never sell or share Apple Health data for advertising.
7. Non-EU transfers
Some providers are based in the US; transfers rely on appropriate safeguards (e.g. Standard Contractual Clauses).
8. Retention
We keep data for the duration of the service and as required by law (e.g. accounting). On account deletion, personal data is removed except what must be kept by law.
9. Your rights
You have the right to access, rectification, erasure, restriction, portability, objection and withdrawal of consent at any time. You can delete your account in Settings. You may lodge a complaint with your data protection authority.
10. Minors
The service is for users aged 16+. We do not knowingly collect data from anyone under 16.
11. Contact
To exercise your rights or for questions: [PRIVACY EMAIL].