Privacy Policy

1. Information We Collect

We collect the following personal data that you provide to us in order to operate the Services:

• Account Data: Your name, email address, and profile picture, obtained through your chosen sign-in provider (Apple or Google).
• Training Goals: Your session frequency goals and preferred days, which you set during onboarding.
• Check-in Data: When you check in to a session, we record the location, time, and the photo you verify with.
• Accountability Connections: A record of the accountability partners you are connected to, in both directions.
• Phone Number (optional): If you choose to use Find Friends, you can add your phone number so that people who already have your number saved can find you on OnTrack. Providing a phone number is optional; the Services remain fully available without one, and you may remove it at any time in Settings. When you first add your number, we tell people who already have it saved that you have joined, showing them your name and profile picture. This happens once, and reaches at most 50 people.
• Contacts (optional): If you grant contacts access in Find Friends, the phone numbers in your address book are sent to us so we can check which of them already use OnTrack. We store them only in a scrambled form that cannot be read back as a phone number, and we never store the names in your address book. Your contacts are never shown to anyone. We keep the scrambled list so that we can tell you when someone in it later joins OnTrack.
• Messages and Reactions: Comments, reactions, and motivation messages you send to other users, stored with your name and delivered to the people you send them to.
• Groups: The groups you join, together with your name, profile picture, and the date you joined, which are shown to the other members of that group. Joining a group also creates an accountability partner connection between you and each of its members, in both directions.
• Support and Reports: If you submit feedback or report a missing venue, we collect the text you write, your email address, the coordinates of the venue where applicable, and basic technical details about your app version and device, so that we can reply and investigate.

We also collect the following data automatically through your use of the Services:

• Device Information: Your device type and operating system version, used for diagnostics and to resolve defects.
• Usage Data: Information about how you interact with the Services, such as completed check-ins and streaks.
• Location Data: When you verify a check-in, we record the precise location (coordinates and the venue name) and store it with that check-in as evidence of attendance. This is visible to your accountability partners. Your coordinates are also sent to Google Places to look up nearby venue names.
• Notification Tokens: A push notification identifier for your device, used to deliver reminders and updates. It is deleted when you sign out.

2. How We Use Your Information

We process your personal data for the purposes set out below. Each is listed with the lawful basis on which we rely under Article 6 of the UK and EU General Data Protection Regulation.

• Providing the Services. Verifying your check-ins and maintaining your streaks. Basis: performance of our contract with you (Article 6(1)(b)).
• Sharing Progress. Displaying your check-ins and streaks to your accountability partners, being those you have added directly and those you are connected to through a shared group. Basis: performance of our contract with you (Article 6(1)(b)).
• Notifications. Sending you reminders and updates regarding your own activity and that of your accountability partners. Basis: performance of our contract with you (Article 6(1)(b)).
• Find Friends. Where you choose to use this feature, matching your contacts and phone number so that you can connect with people already known to you on OnTrack. Basis: your consent (Article 6(1)(a)), which you may withdraw at any time in Settings.
• Telling people you have joined. Notifying users who already hold your phone number that you are now on OnTrack. Basis: our legitimate interests (Article 6(1)(f)) in helping people find those they already know, balanced against the limited and one-off nature of the notification.
• Invite links. Showing limited profile information to someone who opens an invite link you have shared. Basis: our legitimate interests (Article 6(1)(f)) in allowing you to invite people to the Services.
• Improving the Services. Analysing usage trends in order to develop and improve the Services. Basis: your consent (Article 6(1)(a)) where required for analytics on your device, and otherwise our legitimate interests (Article 6(1)(f)) in understanding how the Services are used.
• Security and abuse prevention. Rate limiting, verifying app integrity, and investigating misuse. Basis: our legitimate interests (Article 6(1)(f)) in keeping the Services secure for everyone.
• Support and reports. Responding to feedback, and investigating venues you report as missing. Basis: our legitimate interests (Article 6(1)(f)) in operating and improving the Services, and performance of our contract with you where the request concerns your account.

Where we rely on your consent, you may withdraw it at any time, and doing so does not affect the lawfulness of anything we did before you withdrew it. Where we rely on legitimate interests, you may object to that processing; see section 5.

3. Who Can See Your Data

Your Accountability Partners: Your accountability partners, being those you have added directly and those you are connected to through a shared group, can see:

• Your profile picture and name
• Your session frequency goal, target days, and timezone
• Your current streak
• Your check-in history, including the photos, the time of each check-in, the precise location and venue name, and any caption you add
• When you were last active in the app
• Your holidays and excused days, and the reason you give when you ask to skip a session, which is also included in the notification they receive

Members of Your Groups: Joining a group creates an accountability partner connection between you and every other member of that group, in both directions and without a separate approval step. Those members can therefore see everything an accountability partner can see, including your full check-in history, and you can see theirs. They can also see the date you joined and anything you post in the group. The connection outlasts the group: leaving it does not remove the partner connections it created, which you can remove individually in the app at any time.

Anyone With Your Invite Link: Every OnTrack account has an invite link, created automatically, which you can share to add a partner or invite someone to a group. Anyone who opens that link can see certain profile information, even if they do not have an OnTrack account. For a personal invite link this includes your name, profile picture, and current streak. A group invite link also shows the group's name and photo, together with the names and photos of up to 20 of its members. By using the Services you accept that this profile information is accessible to any person holding your link. You should therefore share it only with people you are content to have access to that information.

Anyone With Your Profile Photo Address: Profile photographs are served from a public address that does not require sign-in, so anyone holding that address can view the image. Check-in photographs are not public: they can be retrieved only by you and your accountability partners.

Service Providers: We engage the following third-party processors to host data and operate the Services: Google Firebase (hosting, database, file storage, sign-in, crash reporting, and push notifications), PostHog (product analytics), Google Analytics, Apple (Sign in with Apple and push notification delivery), Google (Sign in with Google), Google Places (venue lookup), Resend (delivery of feedback and venue reports to our support inbox), GitHub (issue tracking), and Vercel (website hosting and website analytics). These providers process personal data on our behalf and on our instructions, under contractual terms governing security and confidentiality.

We do not sell your personal data to advertisers or third parties.

4. Data Retention

We retain your account data for as long as your account remains active. Where you delete your account, we delete your personal data from our active systems.

Contact data collected through Find Friends, held only in scrambled form, is deleted automatically 90 days after the account that submitted it was last active. Continuing to use the app restarts that period, so the data is kept for as long as the account that provided it remains in use. Deleting your phone number in Settings, or deleting your account, deletes it immediately.

Content you have shared with other users, such as comments, reactions, and messages, remains visible to the people you sent it to after your account is deleted, as it forms part of their own record. Contact us if you would like us to remove it.

Feedback you submit and venue reports you file are kept for 24 months so that we can answer follow-up questions and investigate recurring problems. These are held separately from your account and are not removed when you delete it; contact us if you would like them removed sooner.

Records held by our analytics provider are keyed to an account identifier and are not deleted automatically when you delete your account. Contact us if you would like them removed.

We retain technical logs, which may include account identifiers, for up to 30 days for security and diagnostic purposes.

5. Your Rights

Subject to applicable law, you have the following rights in relation to your personal data:

• Access: To view your history and profile within the Services, and to request a copy of the personal data we hold about you.
• Rectification: To update your name, profile picture, goals, and phone number within the Services at any time.
• Erasure: To delete your account and associated personal data permanently through the in-app settings, or by making a request at ontrackapp.xyz/delete-account.
• Withdrawal of Optional Permissions: To delete your phone number, revoke contacts and location access, and disable notifications at any time, without loss of access to the remainder of the Services.
• Management of Partners: To remove an accountability partner at any time, after which that person no longer has access to your data.
• Objection and Restriction: To object to, or request restriction of, certain processing of your personal data.

If you are in the UK or EU, you also have the right to data portability and the right to lodge a complaint with your local data protection authority (in the UK, the Information Commissioner's Office). To exercise any of these rights, contact us at operations@sesodiatechnologies.com.

6. If You Do Not Use OnTrack

This section is provided for individuals who do not use OnTrack. Where a user of the Services holds your phone number in their address book and elects to use Find Friends, that number is submitted to us. It is provided in accordance with Article 14 of the UK and EU General Data Protection Regulation.

• Personal data held: your phone number, retained only in a scrambled form that cannot be resolved back to a phone number. We do not hold your name.
• Source: the address book of a user of the Services who elected to use Find Friends.
• Purpose and legal basis: to enable users to identify people already known to them on OnTrack. We rely on our legitimate interests under Article 6(1)(f) for this processing.
• Retention: 90 days from the date the address book containing it was last submitted to us, after which it is deleted automatically. Where that user continues to use the feature, each submission restarts that period.
• Recipients: we do not disclose your number to any person who does not already hold it. The user from whose address book it originated continues to see it in their own contacts, as they did before. We do not inform that user, or any other person, that we hold it. The scrambled record we retain is accessible only to the processors identified in section 3, acting on our instructions. It is stored in the United Kingdom, and section 7 sets out the safeguards that apply where personal data is transferred outside your jurisdiction.
• Your rights: without holding an OnTrack account, you may ask us to confirm whether we hold a record corresponding to your number, to restrict or object to its processing, or to erase it. Because we hold the number only in scrambled form, we can act only on a request that supplies the number itself, which we will use solely to locate the record and will not retain. Contact us at operations@sesodiatechnologies.com. You also have the right to lodge a complaint with your local supervisory authority (in the United Kingdom, the Information Commissioner's Office).

We are unable to provide this information to you directly, as we do not hold your number in a form that can be read or contacted. In accordance with Article 14(5)(b), this notice is therefore made publicly available here.

7. International Data Transfers

The Services are operated from the United Kingdom. Our Google Firebase infrastructure is split between the United Kingdom and the United States. Resend and GitHub process personal data in the United States, and PostHog processes personal data in the European Union. Where personal data is transferred outside your jurisdiction, we rely on appropriate safeguards, including standard contractual clauses.

8. Cookies and Similar Technologies

The OnTrack app stores information on your device, and reads information from it, in order to work. Some of this is necessary for the Services to function: your signed-in session, your saved preferences, cached content so that the app is usable offline, and a push notification identifier.

We also use product analytics, provided by PostHog and by Google Analytics for Firebase, which store an identifier on your device and record how the Services are used. These are not necessary for the Services to function. We do not use advertising trackers, and we do not record your screen.

Our website uses Vercel analytics to count visits, and stores a small amount of information in your browser to remember your appearance preference. It does not use advertising cookies.

We do not currently ask for your consent before enabling product analytics. This section sets out exactly what is collected so that you can decide whether to use the Services, and you can ask us at any time to delete the analytics records held about you.

9. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. No method of transmission or storage is entirely secure, and you remain responsible for keeping your account credentials confidential.

10. Contact Us

Questions regarding this policy, or requests to exercise the rights described above, should be directed to:

Sesodia Technologies Limited
New College, Holywell Street, Oxford OX1 3BN, United Kingdom
Registered in England and Wales, company number 16782991
Email: operations@sesodiatechnologies.com

11. Updates

We may amend this policy from time to time to reflect changes to the Services or to legal requirements. Where changes are material, we will notify you through the Services or by email.