mingler / treadmiller / privacy
Privacy Policy
This privacy policy applies to the TreadMiller app for mobile devices, together with any related services operated by TreadMiller (collectively, the “Application”). TreadMiller is hereinafter referred to as the “Service Provider”.
Data Controller Information
TreadMiller acts as the Data Controller responsible for the processing of your personal data.
- Name: TreadMiller
- Email: treadmiller@mingler.digital
For data protection inquiries and to exercise your GDPR rights, please contact the Data Controller using the contact information above.
What information does the Application obtain and how is it used?
The Application and related services acquire the information you supply when you download, access, or register for the service. Registration is not mandatory, but some features may require an account.
Depending on how you use the Application, this may include account information (such as email and display name via Firebase Authentication, Google Sign-In, and/or Telegram login), workout history, treadmill connection metadata, in-app purchase records, and similar service data needed to operate TreadMiller.
The Service Provider may also use the information you provide to send important information, required notices, and, where permitted by law, marketing communications.
Legal basis for processing your personal data
Where the GDPR applies, the Service Provider relies on one or more lawful bases to process your personal data, including:
- Contract performance: processing necessary to provide the Application or fulfil a contract with you.
- Consent: where you have given explicit consent to processing, including for marketing, analytics, advertising, or optional features. You may withdraw consent at any time without affecting processing that occurred before withdrawal.
- Legitimate interests: where processing is necessary for the Service Provider’s specific legitimate interests, such as maintaining network and information security, preventing fraud and abuse, or improving the Application’s core functionality through analytics, provided those interests are not overridden by your data protection rights or fundamental freedoms.
- Legal obligation: to comply with laws or government requests.
Advertising (Google AdMob)
The Application shows advertisements through Google AdMob, including rewarded video ads. AdMob and its partners may collect and process advertising identifiers and other device/usage data to deliver, measure, and personalize ads. Where required (for example in the EEA, UK, and Switzerland), the Application requests consent via Google’s User Messaging Platform (UMP) before personalized advertising.
Learn more: Google advertising / partner sites.
Cookies and similar technologies
The Application or its third-party SDKs may use cookies, SDKs, pixels, and similar technologies to support functionality, analytics, advertising, and service delivery. Where required by law, the Service Provider will obtain your consent before using non-essential tracking technologies.
What information does the Application collect automatically?
The Application may collect certain information automatically, including the type of mobile device you use, unique device identifiers, IP address, mobile operating system, and information about the way you use the Application.
Does the Application collect precise real-time location information?
On some Android versions, approximate or precise location permission may be required by the operating system to scan for nearby Bluetooth devices (FTMS treadmills). Location is used for device discovery / connectivity features, not for mapping or location-based marketing. Aggregated or anonymized diagnostics may be used to improve the Application.
Does the Application use Artificial Intelligence (AI) technologies?
The Application does not use Artificial Intelligence (AI) technologies to process your data or provide features.
Do third parties see and/or have access to information obtained by the Application?
The Service Provider may share your information with third parties as described in this privacy statement. The Application utilizes third-party services that have their own Privacy Policies:
- Google Play Services
- AdMob
- Google Analytics for Firebase
- Firebase Crashlytics
- Firebase Authentication / related Firebase services
- Telegram (if you choose Telegram login / linking)
The Service Provider may disclose User Provided and Automatically Collected Information:
- as required by law, such as to comply with a subpoena or similar legal process;
- when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- with trusted service providers who work on their behalf, do not have an independent use of the information disclosed to them, and have agreed to adhere to the rules set forth in this privacy statement.
Where the GDPR applies, the Service Provider enters into Data Processing Agreements (DPAs) with third-party service providers that process personal data on its behalf, as required by Article 28 of the GDPR.
International Data Transfers
The Service Provider or its third-party service providers may transfer personal data outside the European Economic Area (EEA). Where such transfers occur, the Service Provider will use an appropriate transfer mechanism required by GDPR Chapter V (such as adequacy decisions, Standard Contractual Clauses, or other recognized safeguards).
What are my opt-out rights?
You can stop further collection of information from your mobile device by uninstalling the Application. Uninstalling stops the Application from collecting data from your device, but does not automatically delete information that has already been transmitted to the Service Provider or to third parties.
To request deletion of your personal data, withdraw consent, or exercise any of your rights, contact the Service Provider at treadmiller@mingler.digital.
Data retention
- User Provided Data: retained for the duration of your use of the Application plus 12 months thereafter, unless longer retention is required by law.
- Automatically Collected Data: retained for up to 24 months from collection, unless longer retention is required for legal compliance or security purposes.
- Aggregated and Anonymized Data: retained indefinitely as it no longer identifies you.
- Data required for legal compliance: retained as long as required by applicable law.
Data deletion
You can request deletion of your personal data or account by contacting the Service Provider at treadmiller@mingler.digital. Upon verification of your identity, the Service Provider will delete your personal data from its systems, except where retention is required for legal compliance or legitimate business purposes.
Children’s privacy
The Application is not intended for children under 16 years of age, or where a higher age of digital consent is established under applicable law. The Service Provider does not knowingly solicit data from children or market the Application to them. If you believe a child has provided personal information, contact treadmiller@mingler.digital.
Security
The Service Provider implements physical, electronic, and procedural safeguards to protect information it processes and maintains. However, no security system can prevent all potential security breaches.
Data breach notification
In the event of a personal data breach that poses a risk to your rights and freedoms, the Service Provider will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by applicable law. Where the breach is likely to result in a high risk to your rights and freedoms, the Service Provider will also notify you without undue delay.
Changes to this Privacy Policy
The Service Provider may update this Privacy Policy from time to time by posting the updated policy with an effective date. Where required by law, the Service Provider will seek your consent to material changes before they take effect. Previous versions will be maintained and made available upon request.
Your GDPR data protection rights
Under the GDPR, you may have rights including access, rectification, erasure, restriction of processing, data portability, objection (including an absolute right to object to direct marketing), withdrawal of consent, and rights regarding automated decision-making. You also have the right to lodge a complaint with your local Data Protection Authority (EDPB members). If you are in the United Kingdom, you may contact the ICO.
California privacy rights (CCPA/CPRA)
If you are a California resident, you may have rights to know, delete, correct, opt out of sale/sharing for cross-context behavioral advertising, limit use of sensitive personal information, and non-discrimination. To exercise these rights, contact treadmiller@mingler.digital.
How do you give your consent?
Where processing is based on consent, you provide that consent by affirmatively opting in to the relevant feature or action (including advertising consent forms where shown). You may withdraw consent at any time without affecting processing carried out before withdrawal.
Contact
If you have any questions regarding privacy while using the Application, please contact the Service Provider via email at treadmiller@mingler.digital. The Service Provider will respond within one month of receiving your request, extendable by up to two months where necessary due to complexity or volume, as permitted by applicable law.