Privacy Policy

1. Data controller and contact

Sport Passport is published by Tommaso Giacomo Movis (“we”, the “Publisher”), based in Italy. Name, address, VAT number and email are in the “Publisher and contact” box at the end of this document. For any privacy matter, including the exercise of your rights, write to the email address given. The app is intended for use in Europe.

We are the controller of the personal data we ourselves receive and use: the emails you send us and the technical data of our website pages (see “Our role and yours”). We have not appointed a data protection officer (DPO): the conditions of art. 37(1) GDPR are not met, because we are not a public authority and our core activities consist neither of regular and systematic monitoring of people on a large scale nor of large-scale processing of special categories of data (we do not receive users’ data). We review this assessment when the app changes. Being established in the European Union, we need no representative under art. 27.

2. Our role and yours

The app works on your device and sends us nothing: we do not hold your data and can neither see nor recover it. The data you keep in the app is processed on your device, under your control and for your own purposes. Because we never receive it, have no access to it and decide nothing about it once it is on your device, we are not its controller. We still built the app to protect it (encryption on the device, no accounts, no tracking) and this document describes what the app does with it, so that you can decide with full information.

You decide independently what you export and what you share with others (backup file, PDFs, images, match sheets, messages) and whether to enter data about other people: you are responsible for those operations, and whoever receives the data is independent of us. If you use the app only for personal purposes, this is normally processing for purely personal or household purposes (art. 2(2)(c) GDPR). Apple and Google are independent providers of the services you choose to use with the app (iCloud, Health, Health Connect, device backups) and handle data under their own terms and notices.

We act as controller only in two cases: when you write to us, for example with a request about your rights (see “Purposes and legal bases”), and for the technical data of our website pages, which you reach only if you open a link we published, for example a shared team match link on a device without the app (see “Sharing, recipients and third parties’ data”).

3. What data is processed

On your device the app keeps the following data (we do not receive it):

• Profile: name, title, location, bio, year your career began, the photo you choose as profile picture and, if you enter them, year of birth and maximum heart rate.
• Sports content you enter: sports and levels, results, matches (including names of opponents, teammates and doubles partners), teams, competitions, records, goals and milestones, credentials and other passport items.
• Match sheets you send or receive, their digital signatures and the sender name of a team sheet.
• Cryptographic keys: a data key that encrypts the store on the device and, if you sign team match sheets, a signing key, both in the system keychain (iOS) or keystore (Android).
• Health data read from Apple Health (iOS) or Health Connect (Android), only with your permission and only kept on this device: workouts with sport, date and duration; distance, speed, power, cadence and elevation; heart rate; energy burned. On iOS also workout routes and your date of birth, of which only the year is kept. From this data the app calculates records, totals, heart-rate zones and recaps.
• Settings: language, appearance, sharing choices, reminder schedule (times and days) and your choice about iCloud sync.
• Record of acceptances and choices: versions of the texts accepted, date, language, confirmation that you are at least 18, specific approval of the clauses listed, and your choice about reading health data.
• If you turn on iCloud sync: a random device identifier and technical sync data.
• Temporary copies you create: export files, PDFs and images prepared for sharing.
• Summary for the widgets: if you use the home-screen or lock-screen widgets, the app keeps up to date a small summary of your activity (name and initials, sports and levels, totals of the week, next milestone, sessions waiting for a result, latest session with its duration and heart rate) in a file the widgets can read.

4. Purposes and legal bases

We do not use data for advertising, profiling or any other purpose. The data you keep in the app is processed on your device for the features you use, and no legal basis is needed from us because we are not its controller. For the data we do handle ourselves, the purposes and legal bases are:

• answering the requests, reports and complaints you send us by email: compliance with a legal obligation for the exercise of rights (art. 6(1)(c) GDPR) and legitimate interest for other communications (art. 6(1)(f)); we keep correspondence for as long as needed to answer and then for the applicable limitation period;
• keeping our website pages working and secure (technical data such as the IP address and the page requested, recorded by our hosting provider): our legitimate interest, art. 6(1)(f) GDPR; we do not use this data to profile you or to follow you across sites.

To use the app you must accept the Terms and this Policy and confirm that you are at least 18. Reading health data is optional: if you do not allow it, you can still use the app with the results you enter yourself. The record of your acceptances and choices stays on your device, lets you see what you accepted and is deleted by “Delete all my data”.

5. Health data

Data about your workouts and heart rate is data concerning health, a particularly sensitive kind of personal data (art. 9 GDPR). The app reads it only after your permission, asked on a separate screen before it connects to Apple Health or Health Connect, and only to show it to you. We never receive it.

The app only reads this data and never writes to Apple Health or Health Connect. The data is stored encrypted on your device and is not sent to us. It is also kept out of everything that leaves the device through the app: the backup file you can create and the iCloud sync hold only what you entered yourself, never imported workouts or figures calculated from them. Health-derived data (workout counts, active time, distance, records and totals derived from them, year and season recaps) is excluded by default from share images, the CV and the public passport and appears only if you explicitly include it after a preview. Heart rate and calories are never included.

You can withdraw your permission at any time: in Profile, under Legal, with the Health data consent switch; by disconnecting Health in Integrations; or in the system settings (iOS: Settings > Health > Data Access & Devices; Android: Health Connect > App permissions). After withdrawal the app stops reading; activities already imported stay on your device until you delete them (Profile > Your data > Delete all my data).

Maximum heart rate and heart-rate zones are estimates based on general formulas, not clinical data. The app is not a medical device and gives no diagnosis or medical guidance, as explained in the Terms of Use.

6. Where data is stored, and tracking

Data is stored on your device, in the app’s private storage, encrypted with XChaCha20-Poly1305 using a 256-bit key bound to the device and kept in the system keychain (iOS) or keystore (Android). We do not receive it.

The summary for the widgets is the one exception to the app’s encryption: it is a small file in a storage area shared by the app and its widgets (on iOS an app group, on Android the app’s private area). It is protected by the system’s file protection, is excluded from backups and is deleted by “Delete all my data”. The widgets can show it on the home screen and, if you add them there, on the lock screen, where whoever sees your screen can read it: you can remove the widgets, or hide their content while the device is locked, from the system settings.

The app contains no analytics tools, advertising networks or trackers, does not follow you across other apps or websites and does not ask for tracking authorisation. What Apple and Google collect to run their own stores and services is outside our control.

The app reads the clipboard only when you tap “Paste”, and asks the system whether a messaging app is installed in order to offer you sending with it.

7. Sharing, recipients and third parties’ data

Except for the iCloud sync that you turn on, the app does not send data to anyone on its own. Data leaves the device when you use a sharing feature: the system share sheet (images, PDFs, the backup file, match sheets) or a message you send with the messaging app of your choice. A shared team match link points to our website: the match itself travels after the “#” of the address, which browsers and chat apps never send to a server, so we do not receive it. If you open such a link on a device without the app, the service that hosts our pages records technical data such as the IP address, as described in “Purposes and legal bases”.

You decide what to send and you see a preview before images, PDFs or summary pages are created. Health-derived data is excluded by default and appears only if you explicitly include it. The sample athlete cannot be shared.

Whoever receives what you share is independent of us and responsible for what they do with it: they may copy, forward or alter it, and we cannot take it back. Apple, Google and the apps you use process data under their own notices.

If you enter data about other people (for example the names of teammates, opponents or partners, or names in sheets shared in a group), you are responsible for having a legitimate reason to do so and, if you share it, for having the right to and for informing them. The app does not verify results, does not contact the people named and we keep nothing: if you are a person named, we can explain how the app works, but the data has to be requested from whoever entered it.

8. iCloud, backups and changing device

On iOS you can optionally turn on iCloud sync. The app then keeps a copy of only the data you wrote or chose (profile text, results, matches, goals, settings), never health data or imported workouts, in a private iCloud container of the app, not shown in the Files app and protected by your Apple account. Apple manages that container under its own terms; end-to-end encryption depends on your Apple settings (for example Advanced Data Protection). If you turn sync off you are offered the option to delete the copy; “Delete all my data” always deletes it.

The backup file (Profile > Your data > Export my data) holds what you entered yourself: profile, results, matches, goals and settings. It contains nothing read from Apple Health or Health Connect: no workouts, heart rate, routes, year of birth or maximum heart rate, no records, totals or recaps calculated from them, and no link to a workout. It is not encrypted: whoever has the file can read it, so keep it safe.

Because the data key is bound to the device, after a phone change or a restore from a backup (including iCloud) the app’s encrypted data cannot be read and we cannot recover it. There is no automatic full backup: imported workouts can be read again from Health or Health Connect on the new device; data you wrote can be carried over with the optional iCloud sync or with the backup file.

Device backups (iCloud or computer) may include the app’s files, among them the profile photo, which is protected by the system’s file protection but not by the app’s encryption. These backups are managed by Apple or Google under their terms: we do not receive them and cannot access them.

9. Recipients and transfers outside the European Economic Area

We have no recipients of your data because we do not receive it, and we do not transfer it outside the European Economic Area (EEA). If you use iCloud, Apple, Google, a messaging app or the share sheet, those providers may process data outside the EEA as well, with the safeguards they offer (for example adequacy decisions or standard contractual clauses) and under their own notices; the choice to use them is yours.

Route map (iOS): the route of a GPS workout is read from Apple Health when you open the workout, drawn on Apple Maps and never stored by the app or sent to us. To show the map, the system asks Apple for the map images of the area on screen, as any map app does: Apple handles those requests under its own notice.

10. How long we keep data

Data stays on your device until you delete it. “Delete all my data” (Profile > Your data) removes the store and the data key, imported workouts, the photo, the signing key, temporary files, the record of acceptances and, always, the iCloud copy if one exists, even if you had turned sync off.

If the app cannot read the encrypted store (for example after a restore), it sets the unreadable file aside as a copy with a .corrupt extension instead of deleting it; that copy is kept until the next successful save or until you use “Delete all my data”.

Uninstalling the app removes the local data; on iOS keychain items (cryptographic keys, not readable data) may survive uninstalling and are deleted by “Delete all my data”. Copies outside the app (iCloud, backups, exported files, messages, images and PDFs sent) remain until you delete them there. Emails you write to us are kept as stated in “Purposes and legal bases”.

11. Security

The app’s data is encrypted on the device with XChaCha20-Poly1305; the key is kept in the system keychain or keystore, bound to the device, and there are no passwords to lose. Team match sheets can carry an Ed25519 digital signature of their sender, checked on your device when the sheet is read. The app asks only for the permissions it needs: reading the health data types it uses, optional notifications, the photo you choose and access to iCloud if you turn sync on.

These are the limits: the profile photo and the summary for the widgets are protected by the system’s file protection, not by the app’s encryption; backup files, PDFs and images to share are not encrypted; protection of the iCloud copy is that of your Apple account. No system is perfectly secure.

Because no data reaches us, we cannot detect breaches that happen on your device or your accounts: protect your device (passcode, biometric unlock, updates) and your accounts. If we become aware of a breach involving personal data that we handle, we will take the measures and make the notifications required by arts. 33 and 34 GDPR where they apply. To report a vulnerability write to the email address at the end of this document.

12. Your rights

Under the GDPR you have rights over your personal data. For the data you keep in the app you exercise them yourself, on your device, because we hold none of it:

• Access and portability: Profile > Your data > Export my data (the file holds what you entered yourself, not health data, and is not encrypted; health data stays in Apple Health or Health Connect, where you manage it).
• Rectification: edit your profile and entries in the app; imported data is corrected in the source it comes from.
• Erasure: Profile > Your data > Delete all my data.
• Withdrawing the permission to read health data: Profile > Legal > Health data consent.
• Restriction and objection: turn off the shared sections in Privacy, disconnect Health, turn off reminders or stop using the app.

For the data we ourselves hold (the emails you send us and the technical data of our website pages) and for any other request, write to the email address at the end of this document: we reply within one month, extendable by two further months if necessary (art. 12(3) GDPR). We may be unable to identify you or to find data we do not have (art. 11 GDPR). You have the right to lodge a complaint with the Italian Data Protection Authority, the Garante per la protezione dei dati personali (www.garanteprivacy.it), or with the authority of your country of residence.

13. Children

Sport Passport is not intended for minors: before accepting you must confirm that you are at least 18, and we do not knowingly process data of people under 18. We cannot verify age, because there is no account: the confirmation is your own declaration.

If you are a parent or guardian and discover that a minor is using the app, delete all data from the device (Profile > Your data > Delete all my data) or write to us.

14. Notifications

Reminders are local notifications generated on your device, which you turn on and can turn off at any time; no data is sent to Apple or Google to generate them and the app uses no push notification tokens. The text of a notification may appear on the lock screen and contain information about your activity: you can hide previews in the system settings (for example, on iOS, Settings > Notifications > Show Previews).

15. Automated decisions and profiling

The app makes no automated decisions that produce legal effects or similarly significantly affect you, and does not profile you. Statistics, records, levels and milestones are calculated on your device from your data and are for information only.

16. Changes to this policy

We may update this policy, for example when features or the law change. The version and date are shown at the top. If a change is material, the app asks you to read and accept the new version, which applies to you only from then on, and the screen never blocks the export or deletion of your data.