Privacy Policy

Last updated: 2025-08-17

This Privacy Policy explains how Motitrain ("we", "us") collects and processes your personal data in accordance with the EU General Data Protection Regulation (GDPR).

Data Controller

Motitrain (Data Controller). Contact: ville.tuulos@pilvirouta.com. If appointed, our Data Protection Officer (DPO) can be reached at the same address with subject line DPO.

Categories of Data

• Account data: email and authentication identifiers.
• Usage data: workouts, goals, preferences you store in the app.
• Technical data: device, browser, IP-derived general location, and logs for security.
• Support communications: messages you send to us.

Purposes and Legal Bases (Art. 6 GDPR)

• Provide and secure the service: performance of a contract (Art. 6(1)(b)) and legitimate interests in running a secure service (Art. 6(1)(f)).
• Communications and support: legitimate interests (Art. 6(1)(f)) and, where required, consent (Art. 6(1)(a)).
• Compliance and enforcement: legal obligations (Art. 6(1)(c)).
• Product improvement and analytics in aggregate: legitimate interests (Art. 6(1)(f)); analytics that is not strictly necessary will only run with consent where required.

Recipients and Processors

We use service providers (processors) for hosting, databases, and related services. These providers process data under written agreements with appropriate confidentiality and security obligations. We do not sell personal data.

International Transfers

Where data is transferred outside the EU/EEA, we rely on approved safeguards such as the European Commission Standard Contractual Clauses (SCCs) or adequacy decisions. Copies of relevant safeguards can be requested via the contact above.

Retention

We keep personal data only as long as needed for the purposes above. Typical examples: account data for the life of the account; support messages for up to 24 months; technical logs for up to 12 months unless required longer for security or legal reasons.

Your GDPR Rights

• Access your data and obtain a copy.
• Rectify inaccurate data.
• Erase data (right to be forgotten) where applicable.
• Restrict or object to processing, including processing based on legitimate interests.
• Data portability.
• Withdraw consent at any time where processing is based on consent.
• Lodge a complaint with your local supervisory authority in the EEA/UK.

To exercise these rights, contact ville.tuulos@pilvirouta.com and we will respond within one month where feasible.

Cookies and Similar Technologies

We use strictly necessary cookies for authentication and security. Non-essential analytics or marketing cookies, if introduced, will be used only with your consent. You can change preferences in your browser settings and, if provided, our in-app controls.

Children

Our service is not directed to children under 16 and we do not knowingly collect personal data from them.

Automated Decision-Making

We do not engage in automated decision-making producing legal or similarly significant effects.

Changes

We may update this policy from time to time. The date at the top shows the latest update. Material changes will be communicated through the app or by email when appropriate.

Contact

For questions or requests, email ville.tuulos@pilvirouta.com. If we appoint an EU representative or DPO, their details will be added here.

Reference

Read the full text of the GDPR on EUR-Lex: Regulation (EU) 2016/679 (GDPR).