Privacy Policy

Version 1.0  |  Date: 27/04/2026  |  Effective Date: 27/04/2026

Fidelis Software Limited  |  6 Berryfield Close, Broadwas, Worcester, WR65NJ  |  17157758

IMPORTANT — PLEASE READ BEFORE USING GYMWARS

This Privacy Policy explains how Fidelis Software Limited ("we", "us", "our") collects, uses, stores, and protects your personal data when you use the Gym Wars mobile application ("the App").

Gym Wars processes health and fitness data, which is classified as special category data under UK GDPR and requires a higher standard of protection. By creating an account, you confirm you have read and understood this policy.

If you have questions, contact us at: [email protected]

1. Who We Are


Fidelis Software Limited is the data controller responsible for your personal data. We are registered with the Information Commissioner's Office (ICO) under registration number ZC132262.

For all privacy-related enquiries, you can contact our data controller at:

2. The Data We Collect

2.1 Account and Identity Data


2.2 Fitness and Health Data (Special Category)


The following data is classified as special category health data under UK GDPR Article 9 and receives the highest level of protection we apply:

2.3 Location Data


We collect your precise GPS coordinates for the following specific purposes only:

We do not track your location continuously. Location data is only accessed when you actively tap "Claim Points" at the end of a workout.

2.4 Social and Engagement Data


2.5 Device and Technical Data


2.6 Payment Data


If you purchase a Battle Pass or pay for challenge entry fees, payment processing is handled entirely by Stripe, our payment processor. We do not store, see, or have access to your card number, CVV, or full payment details. We receive only:

3. Why We Collect Your Data and Our Legal Basis


Under UK GDPR, we must have a valid legal basis for every type of data processing. The table below sets out our purposes and the legal basis for each.

Purpose

Data Used

Legal Basis

Creating and managing your account

Identity data, email

Contract performance

Processing workout sessions and awarding GWP

Fitness/health data, location

Explicit consent (Art. 9)

Displaying leaderboards and rankings

GWP scores, username

Legitimate interests

Enabling social features (posts, likes, comments)

Social data, profile

Contract performance

Sending push notifications

Device token, activity data

Consent

Processing payments for Battle Pass

Payment confirmation only

Contract performance

Verifying gym proximity for point claims

GPS location (on demand)

Explicit consent (Art. 9)

Improving app performance and fixing bugs

Anonymised crash data

Legitimate interests

Complying with legal obligations

Identity, transaction data

Legal obligation

Processing injury reports (if used)

Injury location, dates

Explicit consent (Art. 9)

Special Category Data — Your Explicit Consent

Fitness, health, and location data are special category data under UK GDPR Article 9. We only process this data with your explicit, granular consent, which you provide when you create your account. You may withdraw consent at any time — see Section 8 for your rights.

4. How We Store and Protect Your Data

4.1 Where Your Data Is Stored


4.2 Security Measures


We implement a layered security architecture including:

All data at rest is encrypted using AES-256 disk-level encryption

4.3 Data Breach Notification


In the event of a data breach that poses a risk to your rights and freedoms, we will notify the Information Commissioner's Office (ICO) within 72 hours of becoming aware of the breach, and will notify you directly without undue delay.

5. How Long We Keep Your Data


Data Type

Retention Period

Account and profile data

Duration of account + 30 days after deletion request

Workout and fitness data

Duration of account + 30 days after deletion request

Location data (GPS coordinates)

Used in real time to verify proximity — not stored beyond the request

Social posts and comments

Until deleted by you, or account deletion + 30 days

Push notification tokens

Until you log out, uninstall, or revoke permission

Payment records

7 years (UK financial record-keeping legal obligation)

Crash and error logs

90 days (automatically purged by Sentry)

Audit logs (sensitive actions)

2 years

Injury reports

Duration of account + 30 days, or until you delete them

6. Who We Share Your Data With


We do not sell your personal data. We do not share your data with advertisers. We share data only with the following categories of third-party service providers, under contractual data processing agreements:

6.1 Infrastructure and Hosting


6.2 Authentication and Notifications


6.3 Payments


6.4 Communications


6.5 Monitoring and Error Tracking


6.6 Gym Data


6.7 Legal Disclosure


We may disclose your personal data if required by law, court order, or regulatory authority (including the ICO). We will inform you of any such request unless legally prohibited from doing so.

7. Leaderboards, Social Features, and Public Visibility


Gym Wars is a competitive social fitness platform. The following data is visible to other users of the app by default:

The following data is never publicly visible:

Controlling Your Visibility

You can delete any post, comment, or profile content at any time from within the App. Deleted content is removed from public view immediately and permanently deleted from our systems within 30 days.

You can unfollow users and prevent users from following you through your privacy settings.

8. Your Rights Under UK GDPR


You have the following rights regarding your personal data. You can exercise most of these directly within the App, or by contacting us at [email protected].

We will respond to all rights requests within one calendar month. If your request is complex, we may extend this by a further two months — we will inform you if this is the case.

You also have the right to lodge a complaint with the ICO at any time: ico.org.uk | 0303 123 1113

9. Children's Privacy and the Age Appropriate Design Code


Gym Wars is intended for users aged 16 and over. We do not knowingly collect personal data from users under the age of 16.

If you are between 13 and 16, you must obtain parental or guardian consent before using Gym Wars. We reserve the right to verify age and to close accounts where we have reason to believe a user is under 13.

If you believe a child under 16 has created an account, please contact us at [email protected] and we will promptly investigate and delete the account and all associated data.

We comply with the ICO's Age Appropriate Design Code (Children's Code). High privacy protection settings are the default. We do not use nudge techniques designed to encourage children to provide more data than necessary.

10. Cookies and Tracking Technologies


Gym Wars is a mobile application and does not use browser cookies. We use the following device-level technologies:

We do not use advertising tracking, cross-app tracking, or advertising identifiers (IDFA/GAID). Gym Wars does not display advertising and we do not share data with advertising networks.

11. International Data Transfers


Some of our third-party service providers are based outside the UK. Where we transfer personal data internationally, we ensure appropriate safeguards are in place:

You can obtain copies of the relevant Standard Contractual Clauses by contacting us at [email protected].

12. Automated Decision Making and Profiling


Gym Wars uses automated processing to:

None of these automated processes produce decisions with legal or similarly significant effects on you. The leaderboard ranking is for competitive entertainment purposes and does not affect employment, credit, or legal status. You may request a human review of any automated decision by [email protected].

13. Changes to This Privacy Policy


We may update this Privacy Policy from time to time to reflect changes in our practices, new features, or changes in applicable law.

Where we make material changes — particularly changes that affect how we process special category health data — we will:

Continued use of Gym Wars after the effective date constitutes acceptance of the updated policy for changes that do not require fresh consent. For changes that do require consent, you may decline — but this may limit your ability to use certain features.

14. Contact Us and How to Complain

14.1 Contact Us


For any privacy-related queries, data subject requests, or concerns:

14.2 How to Complain


If you are unhappy with how we have handled your personal data, please contact us in the first instance and we will do our best to resolve the matter.

If you remain unsatisfied, you have the right to complain to the Information Commissioner's Office (ICO):

Fidelis Software Limited

Registered in England and Wales  |  Company No: 17157758  |  ICO Registration No: ZC132262.

Document Revision History

Version

Date

Author

Summary of Changes

1.0

27/24/2026

[Matthew Davies]

Updated first copy