Introduction
This Privacy Policy is governed by the General Data Protection Regulation (GDPR) and applies to the LAB 23 app, developed and managed by MitotiM.
The Policy aims to inform users of the LAB 23 app (“Users”) about the collection and processing of their personal data by MitotiM.
Personal Data Collected
MitotiM collects the following personal data from Users:
- Registration Data: name, email, height, weight.
- App Usage Data: data related to workouts performed and interactions with the app.
- Advertising Data (only if consent is given):
- Device identifiers (e.g., IDFA on iOS)
- Device and OS information (model, OS version, app version)
- IP address (used for approximate location)
- Interactions with ads (impressions, clicks)
These data are used to adapt training plans to the user, compare data with other users, and show relevant ads (if consented).
Purpose of Processing
MitotiM processes Users’ personal data for the following purposes:
- User Account Registration and Management: enabling Users to create and manage their accounts via Apple Sign In.
- Provision of Services: providing the features and services offered by the app.
- Personalization: customizing the app experience based on User data.
- Improvement of Services: analyzing data to improve the app and the services offered.
- Statistical Analysis: performing analytics to enhance user experience and app functionality.
- Advertising (only if consent is given):
- Delivering personalized or non-personalized ads through Google AdMob.
- Improving relevance and performance of advertisements.
- Complying with Apple’s App Tracking Transparency framework.
Legal Basis for Processing
MitotiM processes Users’ personal data on the following legal bases:
- Consent of the User: Users provide their consent to the processing of personal data:
- at registration (Apple Sign In)
- via the ATT pop-up for tracking (IDFA)
- Performance of a Contract: to provide the services offered by the app.
- Legitimate Interest: improving app functionality and delivering non-personalized ads (if applicable).
Data Recipients
Users’ personal data may be shared with:
- Technical and IT Service Providers: who act on behalf of MitotiM for app management and service provision.
- Google LLC: as provider of AdMob, which may act as independent controller or processor for advertising data, depending on the context.
- Competent Authorities: to comply with legal obligations.
Advertising and Tracking
The app integrates Google AdMob to display ads. Based on the User’s preferences and consent:
- Personalized Ads may be shown using the IDFA identifier, only if the User explicitly agrees to tracking via Apple’s ATT prompt.
- Non-Personalized Ads may be displayed using contextual information and general device data.
Users can change their preferences at any time in:
- iOS Settings > Privacy > Tracking
- Within the app (if a privacy settings section is implemented)
More information on Google AdMob’s practices:
Data Transfer
Users’ personal data are stored and processed using:
- iCloud and Apple Sign In services (Apple Inc.)
- Google AdMob (Google LLC)
These services may process data outside the European Union, including the United States. Both Apple and Google apply adequate safeguards, such as adherence to the EU Standard Contractual Clauses, to protect Users’ personal data.
Users’ Rights
Users have the right to:
- Access their personal data.
- Rectify or Delete their personal data.
- Limit the processing of their personal data.
- Object to the processing of their personal data.
- Withdraw Consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
- Deny tracking via Apple’s App Tracking Transparency mechanism.
- Opt-out of personalized advertising through Google settings or device-level controls.
- Data Portability: receive their personal data in a structured, commonly used format and transmit it to another data controller.
How to Exercise Rights
Users may exercise their rights by sending a written request to MitotiM at:
📧 info@mitotim.app
Data Retention Period
Users’ personal data will be retained only for as long as necessary to fulfill the purposes for which they were collected, and in any case no longer than required by applicable laws.
Changes to the Policy
MitotiM reserves the right to modify this Policy at any time. The updated version will be published on the website and within the app.
Additional Information
For more information on the processing of Users’ personal data, please contact:
📧 info@mitotim.app