Privacy Policy

This policy tells you which personal data RideTrace uses, why, who receives it, how long we keep it, and what your rights are. It also describes the data that your device generates.

In short:

Who we are: RideTrace. Write to privacy@ridetrace.app.
What we collect: your account, bikes, devices and orders, and your rides with their GPS track.
Why: to record and analyse your rides, to sell the device and membership, to keep the device secure, and to meet the law.
Location: the device records your bike's position during every ride. The start and end often show where you live.
Who receives it: the recipients in our list. Rider data is stored in the EU. Some providers are in the USA. The list gives their safeguards. We do not sell your personal data.
How long: most data stays until you delete it or your account.
Your rights: you can get a copy of your data, correct it, export it and delete it.
Your right to object: you can object at any time to our uses that rely on a legitimate interest, including the membership reminders.
Complaints: write to us, or complain to the Romanian authority ANSPDCP or the authority of your EU country.

Who is responsible for your data

RideTrace is the controller of your personal data. Write to us at the privacy address.

The controller of your personal data is RideTrace, a brand of Late Night Coding S.R.L. ("RideTrace", "we"). The controller is the company that decides why and how your personal data is processed.

Registered office: Pavel Roșca 4, Ap. 28, Cluj-Napoca, Romania
Trade Register (ONRC) number: J12/3071/2023
Fiscal code (CUI): 48501600
Email for privacy questions and requests: privacy@ridetrace.app
Email for other questions: contact@ridetrace.app

We have not appointed a data protection officer. Our processing is not yet on a large scale, so Art. 37 GDPR does not require one. We check this again as RideTrace grows. Send every privacy question to privacy@ridetrace.app.

This policy applies to the device, the RideTrace app, the dashboard at ridetrace.app, the shop and membership. The words "the device", "the RideTrace app", "the dashboard", "membership" and "the subscription" have the meaning that the Terms of Service give them.

What we collect

We collect what you give us, what your device records on your bike, and what RideTrace makes from your rides.

Category	What it contains
Your account	Your email address and name, your time zone, the country your phone is set to when you first accept our Terms in the app, and your settings. The record of the Terms and the Privacy Policy that you accepted, and your confirmation that you are 18 or older. Our sign-in provider also receives sign-in data: the IP address, the time, the browser name and version, the device type and whether it is mobile. It also receives the approximate city and country that the IP address shows.
Your bikes	The details that you enter: nickname, make, model, year, vehicle identification number (VIN), engine type, cooling type, redline and notes. The VIN identifies your bike, and it can identify you.
Your devices	The serial number, the device's other hardware identifiers, its nickname, the hardware and software versions, and the versions of its signal maps. The last IP address from which the device contacted us. Device status data: memory, processor, storage, GPS and bike-network status, Wi-Fi and sync status, restarts and upload errors. Device logs.
Crash dumps	When the device software crashes, the device sends a record of the software's state at that moment. The record includes the memory of the running tasks, and it can contain data that the device held at that moment.
Your rides	For each ride: the start and end time, the distance, the start and end position, and the ride name. A timeline of about 5 rows each second, with GPS position, altitude, speed and heading. Also the values that your bike makes available, such as engine speed, throttle, brake, gear, temperatures and battery voltage. Motion data from the device's motion sensor, such as lean angle. The weather for the ride.
Results about your rides	What RideTrace makes from your rides: ride summaries, scores, coaching and bike-health findings, and route images.
Learning captures	When you teach RideTrace your bike's signals, the device records the raw messages on your bike's data network. A capture also holds the bike's make, model and year, and your confirmation of the safety check before the engine runs.
Signal-map link	Before we publish a signal map made from your learning, we keep a link from the map to its bike and device. While the link exists, the map's review history can also name your account and refer to your learning captures. The retention table says when the link ends. See Signal maps.
Orders and payments	Your name, email address, phone number, delivery and billing address, and a tax ID if you buy as a business. What you ordered, the amounts, the serial number of the device that we ship, and the delivery tracking. Your confirmation that you are 18 or older. Your subscription status and your membership time. Withdrawal requests. See Payments.
Emails	The emails that we send you. A record of each email that we sent, or chose not to send, and why. It holds no email address. Which emails you turned on or off, and when. For product news, the time and the version of the wording that we showed you. Email addresses that bounced or that marked our email as spam. See Emails.
Inbox and phone notifications	The notifications in your app inbox, and which ones you read. The push address of each phone where you use the app and allowed notifications, and whether it is an iPhone or an Android phone. A record of each notification that we sent, or chose not to send, and why, and of Expo's answer for each phone. Which phone notifications you turned on or off, and when. See Inbox and phone notifications.
The waitlist and "Notify me"	Your email address if you join the waitlist. Your email address, bike and country if you ask the shop to tell you when a product is available. See The waitlist.
Visits to our website	When you open a public page of ridetrace.app: the address of the page, the page that sent you, and the steps that you take towards the waitlist or an order. Your IP address and your browser's description also reach Vercel with each request. From them, Vercel finds your approximate location, your browser and your type of device. This data is not linked to your account. See Visit statistics.
Messages to us	What you write to us by email, and our answers.
Other people	If another person rides your bike, the device records that ride in the same way as yours, and the ride goes to your account. A ride can also show that a passenger rode with you, and places where other people were with you. If you have the device delivered to another person, we receive that person's name, address and phone number from you.
Staff access records	When our staff open rider data in our admin console, we log the access: who opened what, and when.

We keep the emails that you send us, and our answers, for the period in the retention table.

Your ride data shows your speed at each moment. It can show that a speed limit was broken. The Terms and Who receives your data say when we give data to third parties.

Where the data comes from:

You give us your account, bike, order and waitlist details, and your messages.
Your device records your rides, its status data, its logs and its crash dumps. It sends them to us.
RideTrace makes the results about your rides from the data that your device recorded.
Stripe, our payment provider, tells us the result of your payment and the details that you gave on its payment page.
Our sign-in provider, Clerk, tells us your email address and name.
Your browser sends the visit data when you open a public page of ridetrace.app. See Visit statistics.

What you must give us:

To have an account, you must give an email address.
RideTrace needs the data that your device records. Without GPS data, for example, we cannot show your route or a replay.
To buy, you must give the payment and delivery details that the checkout asks for.
Other bike details, such as the nickname or the VIN, are your choice.

Why we use your data

We use your data to provide membership, to meet the law, and for a few interests that we name here. We ask for your consent only for the waitlist, "Notify me" and product news.

The GDPR requires a legal basis for each use of personal data. This table gives each purpose and its legal basis. "Art. 6(1)(b)" means that we need the data to perform our contract with you. "Art. 6(1)(c)" means that the law requires it. "Art. 6(1)(f)" means that we have a legitimate interest, which the table names. "Art. 6(1)(a)" means that you gave your consent.

For each legitimate interest, we checked that the interest does not override your rights. You can ask us for the balancing test at privacy@ridetrace.app.

Purpose	Legal basis
Give you an account and let you sign in	Contract, Art. 6(1)(b)
Sync, store and show your rides, with replay, scores, coaching and bike-health findings	Contract, Art. 6(1)(b)
Show a ride on a map, add its weather and name, and make route images	Contract, Art. 6(1)(b)
Teach RideTrace your bike's signals, when you run learning	Contract, Art. 6(1)(b)
Sell and deliver the device, run the subscription and your membership time, take payments, and handle returns and withdrawals	Contract, Art. 6(1)(b)
Send you emails about your account, your orders, your withdrawals and your subscription, and the notices that the Terms require about your account	Contract, Art. 6(1)(b)
Send required notices to a group of riders by email and in the app inbox. They are about a change to our Terms or to this policy, a problem that affects RideTrace, or your safety. We choose who receives each notice from facts about their account. See Emails	Contract, Art. 6(1)(b). Your notification settings do not apply to these notices
Remind you by email before and after your membership time ends, if you have no subscription. The reminders include the price of the subscription and a link to subscribe	Legitimate interest, Art. 6(1)(f): to tell you in time, so that your rides keep syncing. You can unsubscribe or object at any time
Show you notifications in the app inbox, and send them to your phone when you allow it: a new ride, your orders and payments, your withdrawals and cancellations, and your membership	Contract, Art. 6(1)(b). For the membership reminders: legitimate interest, Art. 6(1)(f), the same as for the reminder emails. You can turn each kind of phone notification off in Settings
Send you tips and milestones in the app inbox and to your phone. We choose who receives each message from facts about their account. See Inbox and phone notifications	Legitimate interest, Art. 6(1)(f): to tell you about RideTrace and your progress in messages that fit your account. You can turn them off in Settings, or object at any time
Send you product news by email and in the app inbox, when you turn that on. We choose who receives each message from facts about their account	Consent, Art. 6(1)(a). You can turn it off in Settings, on the dashboard or in the app, or with the unsubscribe link in each of those emails.
Keep invoices, orders and the refunds of withdrawals	Legal obligation, Art. 6(1)(c): Romanian accounting and tax law
Keep withdrawal requests and order records to establish, exercise or defend legal claims	Legitimate interest, Art. 6(1)(f): to prove what you asked for and what we did
Answer your requests about your data rights	Legal obligation, Art. 6(1)(c): the GDPR
Answer an order from a court or an authority	Legal obligation, Art. 6(1)(c)
Use device status data, device logs and crash dumps to find and fix faults	Legitimate interest, Art. 6(1)(f): a device and a service that work and stay secure
Protect RideTrace against abuse and attacks, and log staff access to rider data	Legitimate interest, Art. 6(1)(f): the security of RideTrace and of your data, and proof of who opened rider data
Keep a record of the Terms that you accepted and of your age confirmation	Legitimate interest, Art. 6(1)(f): to be able to show what you accepted
Keep proof that an account or a ride was deleted, or that a device was removed from an account	Legitimate interest, Art. 6(1)(f): to be able to show that the deletion happened, and to defend legal claims. The record holds IDs and counts, but no name or email address
Make anonymous statistics that combine data from many riders, to find faults in the device	Legitimate interest, Art. 6(1)(f): a device and a service that work reliably
Count the visits to the public pages of our website, and how many visitors go from the home page to the waitlist, and through the shop to a paid order. See Visit statistics	Legitimate interest, Art. 6(1)(f): to know which pages help visitors and where they stop, so that we can improve the website. The count uses no cookies, and it is not linked to your account
Keep the link between a signal map and the bike and device that made it, until we publish the map. Our staff use the link to check the map	Legitimate interest, Art. 6(1)(f): to check a map before other riders install it and rely on it. See Signal maps
Use your learning captures to check a signal map before we publish it for other riders	Legitimate interest, Art. 6(1)(f): the quality of the RideTrace library, so that the signal maps that other riders install work. Only our staff use the captures, only to check the map that those captures made, and only until we publish it. So the interest does not override your rights
Record and show the rides of other people who ride your bike, and deliver to a person that you name	Legitimate interest, Art. 6(1)(f): to give the account holder membership and the delivery that they asked for
Answer your messages	Contract, Art. 6(1)(b), when the message is about your contract. Otherwise legitimate interest, Art. 6(1)(f): to answer you
The waitlist, and "Notify me" in the shop	Consent, Art. 6(1)(a). See The waitlist

A published signal map is not personal data, so it needs no legal basis. See Signal maps.

You can object at any time to a use that relies on a legitimate interest. See Your rights.

We use your data only for the purposes in this table. If we want to use it for a new purpose, we tell you first.

The waitlist

If you join the waitlist, we use your email address only to invite you to RideTrace. You can withdraw your consent at any time.

When you join the waitlist on ridetrace.app, you give us your email address. We use it only to invite you to create a RideTrace account.
The legal basis is your consent, Art. 6(1)(a) GDPR.
Our sign-in provider, Clerk, holds the waitlist for us, and Clerk sends the invitation. Your email address goes to Clerk. It does not go to our own database.
We keep your email address until we invite you, or until you withdraw your consent. See the retention table.
You can withdraw your consent at any time. Write to privacy@ridetrace.app. We then remove your email address from the waitlist. The withdrawal does not affect what we did before it.

"Notify me" in the shop works the same way. If you ask the shop to tell you when a product is available, we use your email address, bike and country only for that email. We send that email ourselves. The legal basis is your consent, Art. 6(1)(a). We record which consent text you accepted. We delete your request after we notify you, or after the period in the retention table. To withdraw your consent, write to privacy@ridetrace.app.

Payments

Stripe handles your payment. We never see your card number. A courier delivers your device.

You pay by card on the payment page of Stripe, our payment provider. You enter your card details only on Stripe's page. We never see your card number.
For a device order, Stripe asks for your delivery address, your phone number and, if you buy as a business, a tax ID. For the subscription, Stripe asks for your billing address and, if you buy as a business, a tax ID.
We send Stripe what it needs to take the payment: what you ordered, the amounts, your country and a reference to your order.
For the subscription, we also send your account email address and name, your RideTrace account reference, the plan and the membership dates.
Stripe tells us the result of the payment and the details that you gave on its page. We keep them with your order.
Stripe makes the invoice. Stripe keeps its own records of your payments and invoices. When you delete your RideTrace account, those records stay with Stripe.
We give your name, delivery address and phone number to the courier. The courier uses them to deliver the device and to contact you about the delivery.

The list of recipients gives Stripe's role, its location and the safeguard for your data.

Emails

We send you emails about your account, your orders, your withdrawals and your membership. We also send required notices about our Terms, this policy, a problem with RideTrace or your safety, and product news if you turn it on. Some reminders include the price of the subscription.

We send these emails through Resend, our email provider:

the confirmation and the shipping notice of an order
the acknowledgement and the outcome of a withdrawal
the acknowledgement of a cancellation
notices about the grace period after a failed payment
reminders that your membership time, for example your included membership, is ending, if you have no subscription
a notice when your membership ends, and a follow-up after it ended, if you have no subscription
the notices that the Terms require. Examples are a price change, a change to the Terms or membership, a suspension, a safety warning, or the end of membership
notices about a change to this policy, or about a problem that affects RideTrace
product news, only when you have turned it on in Settings

For an order, we send the emails to the email address that you gave at checkout.

Required notices have no unsubscribe link, and your notification settings do not apply to them. Some concern only your account, for example a suspension. Others go to all riders, or to a group that we choose from facts about their accounts. An example is the riders who have a device.

A notice to a group of riders also appears in your app inbox. Its email states the reason we sent it. The reasons are a change to our Terms of Service, a change to our Privacy Policy, a problem that affects RideTrace, and your safety. We send notices to a group only for these reasons, and never for product news.

The reminders, the notice when your membership ends and the follow-up include the price of the subscription and a link to subscribe. Each of these emails ends with a "Stop these reminders" link. It works without signing in. You can also turn the reminder emails off in Settings, under Emails, on the dashboard or in the app. Emails about your orders, payments, cancellations and withdrawals still arrive. You can also object at privacy@ridetrace.app.

Product news is off until you turn it on. While it is on, each product news message also appears in your app inbox. You can turn it off in Settings, on the dashboard or in the app, or with the unsubscribe link in one of those emails. Turning it off stops product news in your email and in your app inbox. Emails about your orders, payments, cancellations, withdrawals, and membership still arrive.

Resend does not keep a contact list of riders. We send each email through Resend. Resend receives the email address, the content and the headers of that email. For a reminder or product news, the headers include the unsubscribe link of the email.

When you turn product news on, we record the time and the version of the wording that we showed you.

We keep a record of each email that we sent, or chose not to send, and why. It holds no email address. We keep it for 24 months. The record of the email that confirmed we received your withdrawal is the exception. We keep it as long as the withdrawal request, as proof that we confirmed it. See the retention table. If an email cannot be delivered to an address at all, or the person marks our email as spam, we keep that address until our staff remove it, so that we stop sending to it.

Clerk, our sign-in provider, sends your sign-in codes. If you joined the waitlist, Clerk also sends your invitation.

Inbox and phone notifications

The RideTrace app and the dashboard show notifications in an inbox. When you allow it, the app also shows them on your phone. Phone notifications pass through Expo, and then Apple or Google.

What we send to the inbox and to your phone:

a new ride is ready: inbox and phone
an order is confirmed: inbox only. An order ships: inbox and phone
the notices about the grace period after a failed payment: inbox and phone
the membership reminders, the notice when your membership ends, and the follow-up after it ended: inbox and phone
the acknowledgement of a cancellation, and the acknowledgement and the outcome of a withdrawal: inbox only
tips and milestones: inbox and phone
product news, while it is on, and the required notices to a group of riders: inbox only. They also arrive by email. See Emails

These notifications go only to your account. An order that you placed without signing in gets emails only. The emails about orders, payments, cancellations and withdrawals arrive as before. A notification does not replace them.

The phone permission:

The app asks for permission to show notifications at the end of device setup. You can also allow them in Settings in the app.
If you allow them, the app asks Expo for a push address. For this, the app sends Expo the phone's Apple or Google push token, an installation ID of the app, the app's ID, and whether it is a development build. Expo also sees the phone's IP address.
The app then sends us the push address. We use it only to send notifications to the app on that phone.
If you do not allow them, nothing goes to your phone. The notifications still appear in the inbox.
You can turn notifications off in your phone's settings at any time.
When you sign out of the app, it asks us to delete the push address of that phone.

What a phone notification contains:

a title and a short text. For a new ride, the distance and the duration, but not the ride name. For an order, the order number, and the carrier and tracking reference when it ships. For a payment, a membership reminder or the notice that your membership ended, the date. The notice that your membership ended and the follow-up can say how much your device had waiting to sync, and on which date. For tips and milestones, the start of the message
what the notification opens, for example a ride, an order or a page on ridetrace.app, and its inbox item
never your location or an address. Your phone can show the notification on the lock screen

In Settings, you can turn off each kind of phone notification: new rides, orders and payments, membership reminders, and tips and milestones. In the app, they are under Notifications. On the dashboard, they are under Phone notifications. Each switch applies to every phone where you use the app.

The inbox has no switch of its own:

Some notifications stop arriving in the inbox when every switch for them is off. They are the membership reminders, the notice when your membership ends and its follow-up, tips and milestones, and product news.
For the membership reminders and the two membership notices, these are the Membership reminder emails switch and the Membership reminders phone switch. For tips and milestones, it is the Tips and milestones switch. For product news, it is the Product news switch.
Every other notification always arrives in the inbox.

Tips and milestones:

These are our messages about riding with RideTrace and about your progress. Our staff write them.
They are on until you turn them off. The Tips and milestones switch stops them on your phone and in the inbox.
You get at most one message of tips and milestones or product news in 24 hours.

We choose who receives tips and milestones, product news and the required notices. For each message, our staff choose a rule that they wrote over these facts about your account:

the date that you signed up
your rides: how many, the date of the first and of the latest, and the total distance. For each ride: when it started and ended, its distance and moving time, and which bike and device recorded it
your bikes: how many, and for each one the make, model, year, engine and cooling type, whether you set a redline, and when you added it
your devices: how many, and for each one the hardware revision, firmware version, the bike software it runs, when you claimed it, when it was last online and last uploaded a ride, and its health status
your riding: your rider level and tier, the scores of each ride, the number of harsh braking and acceleration events, and the type and state of the coaching notes and bike health warnings about your rides and bikes
your orders and subscription: how many paid orders you have and the date of the latest, the status of each order, the country we ship it to, the bike and harness it is for, and your plan, its state and whether you cancelled it
your country: the country we ship your latest order to, or else the country your phone was set to when you signed up in the app
which phones have the app for notifications (iPhone or Android), and the versions of our Terms and this policy on your account
your membership: whether it is on, when it ends, and whether you are in the grace period after a failed payment
whether the app can send notifications to a phone of yours
whether product news and Tips and milestones are on, and your time zone

We do not use your name, your email address, your phone number or address, your bike's nickname or VIN, your notes, your speed, or where you rode for this choice. Everyone who receives a message gets the same text.

When Tips and milestones is off, we leave you out of every tips and milestones message before we prepare it. When product news is off, we do the same for product news. The required notices do not depend on your switches.

This choice is profiling under the GDPR. The legal basis depends on the message.

For tips and milestones, the legal basis is our legitimate interest, Art. 6(1)(f): to send you messages that fit your account. For product news, it is your consent, Art. 6(1)(a). For the required notices, it is our contract, Art. 6(1)(b).

To object, turn off Tips and milestones or Product news in Settings, or write to privacy@ridetrace.app. You cannot turn off the required notices.

Expo (650 Industries, Inc., USA), our push provider, receives the push address, and the title and the text of each phone notification. It also receives the ride ID, order number or page that the notification opens. From the app, it receives the phone's Apple or Google push token and an installation ID of the app, to make the push address, and it sees the phone's IP address. Expo passes the notification to Apple for an iPhone, or to Google for an Android phone. Apple or Google delivers it to the phone. If Expo tells us that a phone no longer accepts notifications, we stop sending to it.

We keep a record of each notification that we sent, or chose not to send, and why. It holds no email address and no push address. We also keep Expo's answer for each phone notification. The retention table gives how long we keep the inbox, the push addresses and these records.

Location

The device records the position of your bike during every ride. The start and the end of a ride often show where you live or work.

The device records the position of your bike from the start to the end of every ride.
The start and the end of a ride usually show where you keep your bike. That is often where you live. Your rides can also show where you work and your regular routes.
The RideTrace app and the dashboard show your rides only to you. Our authorised staff can also see them in our admin console. See Who receives your data.
The device also keeps its last GPS position in its internal memory. See Data on the device.

To add information to a ride, our server sends parts of its position to public services:

Weather: one position, the centre of the ride's track, and the ride's dates go to Open-Meteo.
Ride name: two positions go to Nominatim of the OpenStreetMap Foundation. These are the start and the end, or for a round trip, the start and the point furthest from it.
Map data: the area of the ride goes to the Overpass API, to get map data for that area.

When you look at a map in the RideTrace app or the dashboard, your phone or browser loads the map from our own map server. It also loads the terrain and the label fonts from there. The map server keeps no record of your IP address or of the area that you look at.

What you can do:

Delete a ride, or remove a recording, that you do not want to keep. See Your rights.
Before you give your bike or your device to another person, reset the device. See Data on the device.
Tell a passenger, or a person who rides your bike, that the device records the ride.
If a person rides your bike for work, for example an employee, you must inform them before they ride. The law on monitoring at work can set further conditions.

Data on the device

The device keeps your rides on its memory card until they sync. It keeps your Wi-Fi passwords and its last GPS position in its internal memory, which is encrypted. The memory card is not encrypted. A person who has the card can read the files on it.

On the memory card:

Rides: the device writes each ride to the memory card as plain-text files. After a file syncs to RideTrace, the device deletes it from the card. A file that has not synced stays on the card.
Learning: when you teach RideTrace your bike's signals, the device keeps the captures and what it learned on the memory card.
Crash dumps: the device keeps crash dumps on the memory card until they upload.

In the internal memory:

Wi-Fi: the names and passwords of up to 8 Wi-Fi networks.
Last position: the device's last GPS position, so that it finds its position faster at the next start.
Paired phones: the Bluetooth pairing keys of up to 4 phones.
Identity: the device's ID and upload key, and your name, or your email address if your account has no name.
Nickname: the name that you gave the device.
Setup code: the setup code of the device. It belongs to the device and stays on it.

The device encrypts its internal memory. It does not encrypt its memory card. A person who steals the device or the card can read the files on the card. These files show where you rode, and they can show where you live. You can take the card out and read the files on a computer.

What a reset erases:

Reset the device to factory settings in the RideTrace app erases the ride files, the learning files, the crash dumps and the software update files on the memory card. It also erases the Wi-Fi networks, the last position, the paired phones, the nickname and the identity from the internal memory. The reset also removes the device from your account.
The reset does not erase the setup code.
If you hold the button on the device for 10 seconds, the device erases only its internal memory. That is the Wi-Fi networks, the last position, the paired phones, the nickname and the identity. It does not erase any file on the memory card.

To remove every file, reset the device in the RideTrace app. Then take out the memory card and erase it on a computer.

Deleting your RideTrace account does not erase the data on the device. Reset the device before you delete your account, and before you sell or give away the device.

Data on your phone

The RideTrace app keeps your sign-in and the setup codes of your devices in the phone's secure storage. It also keeps a copy of recent data so that it opens quickly.

What the RideTrace app stores on your phone:

Sign-in: your sign-in session, in the phone's secure storage. On iOS this is the Keychain. On Android, the Android Keystore encrypts it.
Your devices: the setup code of each device that you paired, in the secure storage. When you remove a device from your account in the app, the app removes its code.
Recent data: a short-lived copy of the data that the app last showed you, such as your rides and your bikes. The app keeps it so that it opens quickly. The copy does not include ride replays. When you sign out, the app clears this data from the app.
Learning: while you teach RideTrace your bike's signals, the app keeps the captures until RideTrace accepts them.
Notifications: the push address of the phone and when the app last sent it to us, until you sign out. Also your answer to the notification question at the end of device setup. See Inbox and phone notifications.

On Android, the secure storage and the copy of recent data are not included in cloud backups or in a transfer to a new phone.

The RideTrace app never reads or stores your phone's location. It contains no analytics, advertising or tracking tools.

Permissions that the RideTrace app asks for:

Bluetooth: to connect to the device, for setup, status, live values and learning. The app uses Bluetooth only while it is open.
Location, only on Android 11 and older: Android requires this permission to scan for Bluetooth devices. The app does not use your location. On Android 12 and newer, and on iOS, the app does not ask for location.
Camera: only to scan the setup code of the device. The app does not ask for the microphone.
Notifications: to show notifications on the phone. The app asks at the end of device setup. See Inbox and phone notifications.

Who receives your data

Service providers and a few other recipients receive your data. Some are outside the EU. Our staff see rider data only when they need to, and we log their access through our admin console.

Rider data is stored in the EU, on servers we run ourselves or rent from Amazon Web Services (EU region). We also keep an encrypted backup copy of it in the EU, at Cloudflare. Cloudflare does not have the key.

These service providers and public services receive personal data. The table says what each one receives, where it is, and the safeguard for data that leaves the European Economic Area (EEA).

The "Role" column says how each recipient can use your data. A "Processor" uses it only on our instructions. An "Independent controller" also decides itself how it uses the data. A "Public service" is a service that we send limited data to, for one purpose.
The "Safeguard" column uses two short names. "DPF" is the EU–US Data Privacy Framework. "SCCs" are the standard contractual clauses of the European Commission. Both are explained below the table.

Name	Role	Purpose	Data it receives	Location	Safeguard
Clerk	Processor	Rider sign-in and account identity (authentication)	name, email address, sign-in data: IP address, time, browser name and version, device type, whether the device is mobile, and the approximate city and country from the IP address, time zone, waitlist email addresses	USA	DPF
Vercel	Processor	Hosts our website and the web dashboard, serves rider requests, and counts the visits to the public pages of the website (Vercel Web Analytics, without cookies)	IP address, web traffic metadata, the dashboard data that it serves and caches: account, bikes, rides and their positions, and results, the admin-console pages that show rider data to our staff (not cached), for the visit statistics, on the public pages only: the page address without its query (only campaign tags are kept), the page that sent the visitor, the waitlist and shop steps, and the browser, operating system, type of device and approximate location that the request shows	USA	DPF
Amazon Web Services	Processor	Hosting of the API, database and file storage, when we use rented servers instead of our own	all rider, device and order data processed by the platform	EU region	EU region; AWS DPA; also EU-US DPF-certified
Cloudflare	Processor	Stores the daily backup of our database and stored files (Cloudflare R2). We encrypt the backup before it leaves our server, and Cloudflare does not have the key	an encrypted copy of all rider, device and order data in our database, an encrypted copy of crash dumps and device software files	EU	Stored in the EU (R2 EU jurisdiction); Cloudflare DPA; also EU-US DPF-certified
Stripe	Independent controller	Payment processing for device orders and the subscription. Stripe takes payments on our instructions, and is an independent controller for its own legal duties, such as fraud checks and its payment records	order and payment details, name and email address, your RideTrace account reference (subscription), billing address, shipping address, phone number, tax ID (if you buy as a business), payment method details (we do not see card numbers)	USA	DPF
Resend	Processor	Sends our emails: orders, withdrawals, account notices, membership reminders (you can unsubscribe), and product news (only if you turn it on)	the email address of the email it sends, the content of that email, the headers of that email, which can include its unsubscribe link	USA	DPF
Expo (650 Industries, Inc.)	Processor	Delivers the app's phone notifications (Expo Push Service). Expo passes each notification to Apple (APNs) for an iPhone or to Google (Firebase Cloud Messaging) for an Android phone, which deliver it to the phone	the push address (Expo push token) of each phone where you use the app and allowed notifications, the title and the text of each phone notification: ride distance and duration, order number, shipping carrier and tracking reference, membership and payment dates, and the size of the recordings waiting on the device when the service ends, what the notification opens: a ride ID or an order number, and the ID of its inbox item, from the app, to make the push address: the phone's Apple or Google push token, an installation ID of the app, the app's ID and project ID, and whether it is a development build, the IP address of the phone when the app asks for its push address	USA	SCCs
Open-Meteo	Public service	Looks up the weather shown for a ride	one GPS coordinate (the centre of the ride's track), the ride's time window (its start and end dates only)	Switzerland	adequacy decision (Switzerland)
Nominatim (OpenStreetMap Foundation)	Public service	Reverse-geocodes a ride's start and end coordinates into a readable ride name	two points of the ride: start and end, or start and the furthest point for a loop ride	EU	EU
Overpass API	Public service	Map data for the area of a ride	the area of a ride: a rectangle around its track	EU	EU
Time servers (NTP Pool, pool.ntp.org)	Public service	Sets the device's clock	the device's public IP address when it sets its clock (no rider identifier is sent)	Worldwide (volunteer servers)	None established; no rider identifier is sent

Other recipients:

Recipient	Why	What it receives
The courier that delivers your device	To deliver the device and to contact you about the delivery	Your name, delivery address and phone number, and the parcel
Our accountant	To keep our accounts, as Romanian accounting law requires	Your order and invoice details
The Romanian tax authority (ANAF)	To meet Romanian tax law	Invoices and accounting records, as the law requires

Transfers outside the EEA:

Some recipients are in the USA or in Switzerland. The "Safeguard" column gives the legal basis for each transfer.
"DPF" means the EU–US Data Privacy Framework. The European Commission decided that it protects personal data adequately.
"SCCs" means the standard contractual clauses that the European Commission adopted.
The European Commission decided that Switzerland protects personal data adequately.
The time servers of the NTP Pool are run by volunteers around the world. The device sends them no rider identifier.
To get a copy of a safeguard, write to privacy@ridetrace.app.

Resend, our email provider, receives the email address, the content and the headers of each email that we send. The headers can include the unsubscribe link of the email. It keeps no contact list of riders. See Emails.

Expo, our push provider, receives the push address of your phone, the title and the text of each phone notification, and the ride ID or order number that it opens. From the app, it receives the phone's Apple or Google push token and an installation ID of the app, to make the push address, and it sees the phone's IP address. Expo passes the notification to Apple or to Google, which deliver it to your phone. See Inbox and phone notifications.

Vercel hosts our website and the dashboard. When you use them, your browser's requests pass through Vercel. Vercel also keeps a server-side cache of the dashboard data that you last viewed. On the public pages of the website, Vercel also counts the visits for us. See Visit statistics. The table gives Vercel's location and safeguard.

Our staff:

Our authorised staff can see rider data in our admin console. They open it when they need to support you, or to fix a fault in your account, your rides or your device. They work under confidentiality.
We log staff access to rider data through the admin console.

Requests from third parties:

The police, an insurer, a court or another third party can ask us for your data. We give it only when a valid order under EU or Romanian law requires us to.
We tell you about the order, unless the law forbids it.

We do not sell your personal data. We do not use it for advertising.

Every signal map goes to the RideTrace library for its bike model. A published signal map holds nothing about you, and it is not personal data.

When you run learning on your bike, RideTrace makes a signal map for your bike model. The signal map tells a RideTrace device how to read that model's data. The Terms give the rules for signal maps.

How sharing works:

Every signal map goes to the RideTrace library for the bike model that it was made for. After we check and publish it, other riders with that model can install it.
There is no setting to keep a signal map private. If you do not want to contribute a map, do not start learning. You can still install maps that other riders made.
If RideTrace does not read your bike model yet, the device does not record rides until you run learning. See the Terms.
The RideTrace app tells you about sharing on the first learning screen, before you start.

What a published signal map holds:

The library keeps the signal map and the make, model and year that it was made for.
It does not keep your name, account, bike, device, VIN, rides or locations. It does not keep the time when you ran learning.
Other riders never see who made a map.
A signal map describes a bike model, not a person. After we publish it, nothing in it identifies you. So a published map is not personal data, and the GDPR does not apply to it.

The link before we publish a signal map:

Until we check and publish a signal map, we keep a link from the map to the bike and the device that made it. This link is personal data.
Why: our staff use the link to check the map against the learning captures that it was made from. We do this before other riders install the map and rely on it.
Legal basis: legitimate interest, Art. 6(1)(f). See Why we use your data.
Who sees it: apart from you, only our authorised staff, in our admin console. We log staff access to rider data through the admin console.
How long: we delete the link when we publish the map. We also delete it when you delete that bike or your account, or remove the device from your account. Otherwise, we delete it within a day after the period for which we keep learning captures ends. That period counts from when you first submitted the map. The retention table gives that period.
When we delete the link, the map stays. We can still check and publish it.

What stays linked to you:

Your learning captures are your personal data. We use them to perform our contract with you, Art. 6(1)(b). We keep them for the period in the retention table.
We also use your learning captures to check a signal map before we publish it. For that use, the legal basis is legitimate interest, Art. 6(1)(f). See Why we use your data.
Nothing links your learning captures to a published signal map.
Your bike receives published signal maps the same way every rider's does. We keep no record of who made a map.
When our staff open a signal map before we publish it, we record the access. After the link ends, our staff access record can still show that staff looked at a signal map of yours awaiting review. It does not show which map. We keep it for 12 months, and we delete it with your account.

Signal maps on other riders' devices:

A signal map that other riders already installed stays on their devices.
When you delete your account or ask us to erase your data, the map stays in the library and on those devices. We do not recall it.

AI

We do not send your data to AI models.

We do not send your data, your rides or your bike's data to an AI model.
Signal maps come only from learning on riders' bikes. See Signal maps.

If this changes, we update this section and the list of recipients first.

How long we keep your data

We keep most data until you delete it or your account. The table gives a fixed period for some records, and the law sets the period for others.

Data	How long we keep it	Notes
Your account	Until you delete your account. If you never accept the Terms and your account has no device, bike or ride: deleted 30 days after you create it	Stripe keeps its own record of you as a customer. See Payments in this policy.
Your bikes	Until you delete the bike, or your account
Bike-health summary of each bike	With the bike: until you delete the bike, or your account	Deleted or updated when you delete rides.
Calibration of each bike's speed and temperature readings	With the bike: until you delete the bike, or your account
Device-to-bike installation links	Closed when the device is released; deleted with the bike
Device claim tokens	Deleted by the account purge
Rides	Until you delete the ride (deleted 30 days after you delete it) or your account
Recording sessions	With their ride: until you delete the ride (deleted 30 days after you delete it) or your account. A recording that is on no ride and that you remove: deleted 30 days after you remove it
Ride segments	With their ride: until you delete the ride (deleted 30 days after you delete it) or your account
Ride join corrections	With their recording sessions: until you delete the ride (deleted 30 days after you delete it) or your account
Ride timeline (GPS, motion and bike values)	With the ride, at full detail; no separate age limit	Compressed (not deleted or reduced in detail) after 30 days for storage efficiency.
Ride session event log	With the ride
Session summaries	With their session (and so with the ride)
Ride summaries	With their ride
Graded manoeuvres	With their ride
Your rider level	Until you delete your account
Coaching insights	With their ride
Findings (bike-health and coaching)	With their ride, session or bike; findings about you are kept with your account
Device status snapshots (raw)	30 days, then rolled up into a daily summary	The daily summary is kept for as long as you own the device. Both are deleted when you remove the device from your account or delete your account.
Device status, daily summary	For as long as you own the device; no separate age limit	Deleted at device release and at account deletion.
Crash coredump files	90 days from receipt
Learning captures from your bike's data network (raw)	90 days from capture	Raw learning captures. Not linked to any published signal map.
Learning session record: the signal map your phone sent, the steps it flagged, and the bike and device	90 days from when your phone sent it	Deleted together with the learning captures, also when you remove the device from your account or delete your account. Deleting it does not delete the signal map from the shared library.
Signal maps (shared library)	Kept indefinitely	Kept in the shared library; staff can withdraw a map that is wrong. Not linked to you: no account, bike, device, VIN, rides or locations. There is no sharing setting, and a signal map is not deleted when you delete a bike or your account.
Link from a signal map to the bike and device that made it	Until the map is published. At the latest, the link ends within a day after 90 days from when the map was first submitted	Kept only while the map waits for review. Deleted when the map is published, when you delete that bike or your account, or when you remove the device from your account, if that comes first. Until then, the map's review history also names the account that submitted it and refers to the learning captures; whenever the link ends, the review history stops naming you.
Uploaded files never linked to a ride	30 days
Uploaded files linked to a ride that has not finished processing	90 days
Operational device logs (info/debug)	30 days
Device warning/error logs	12 months from receipt	Records of a deletion are kept with no end date, as proof of the deletion. This covers an account, a ride or a device removed from an account. They hold internal IDs and counts, but no name or email address.
Staff access log to rider data	12 months	After a signal map's link ends, the record no longer names the map.
Deleted-account tombstones	30 days	A one-way hash only, used to stop a deleted account being silently recreated.
Your data export files	7 days from completion	A failed export is deleted 7 days after you asked for it.
Backup copies of our database and stored files	Up to 31 days for each copy	Encrypted. Data that you delete stays in the copies made before, until they are deleted.
Orders and invoices	10 years	Kept as an accounting and fiscal record, not tied to your account, per Romanian accounting law.
Order status history	10 years, with its order	Kept as part of the same accounting and fiscal record as its order.
Withdrawal (right-to-cancel) requests	10 years	Kept as a contract record, the same as an order.
Your subscription record	Deleted with your account	Mirrors Stripe for display and support only; Stripe's own invoice is the fiscal record.
Your included-membership ledger	Deleted with your account	Not a fiscal record; it only tracks the membership months you are owed.
Notifications waiting to be sent (email, phone notification and app inbox), with the facts each one states	30 days after the notification is handled	Deleted with your account.
Records of each notification we sent or did not send (email, phone notification and app inbox), and why	24 months	Holds no email address and no push address. It is not deleted with your account: it stays for the rest of its 24 months, without the link to it. The record of the email that confirmed we received your withdrawal is kept as long as the withdrawal record.
Email addresses that bounced or marked our email as spam	Until staff remove it	We stop sending to such an address. After a bounce, this includes order and payment emails. After a spam complaint, those emails still arrive.
Your settings: time zone, which emails and phone notifications you turned on or off, when, and whether in Settings or through an unsubscribe link, and the product news consent wording version	Deleted with your account	Kept with your account record. Each change replaces the one before it.
Notifications in your app inbox	12 months	Deleted with your account.
The push address of each phone where you use the app	We delete it when you sign out of the app on that phone. If Expo tells us the phone no longer accepts notifications, we delete it 90 days after that	Deleted with your account.
Records of each phone notification handed to Expo for Apple or Google	30 days	Deleted with your account.
The rules we use to choose which riders get tips and milestones, product news and required notices, written over account facts such as signup date, rides, devices, membership and orders	Until our staff archive the rule, then 24 months	Staff configuration with no contact details. A rule chooses riders by account facts. We do not put lists of riders in it.
Messages we write for a group of riders (tips, product news and required notices): the text, the link, the schedule and the rule that chooses the riders	Until our staff archive the message, then 24 months	Staff configuration. It holds no data about riders. Each copy we send you is a notification and is kept as the notification rows above say.
Counts for each sending of such a message: how many riders the rule matched, how many messages we queued and how many riders already had it	24 months	Counts, and an error message when a sending fails. It does not list riders. An error message can, rarely, repeat one value that the rule read.
Stripe webhook event records	90 days from receipt
"Notify me" waitlist requests (out-of-stock shop items)	12 months, or immediately once you are notified
Waitlist email addresses (held by Clerk)	Until we invite you, or until you withdraw your consent	Owner to confirm.
Visit statistics of the public pages of our website (held by Vercel)	At least 12 months, the reporting period of our Vercel plan. Vercel can keep them longer	Vercel deletes the code that it counts a visitor with after 24 hours. The records hold no IP address, and they are not linked to your account.
Emails you send us, and our answers	3 years after your last message	Owner to confirm.
Your Terms/Privacy acceptance history	Until account deletion	Kept as an append-only history while your account exists.
Device hardware identity	Kept indefinitely as the device's hardware record	Kept with no end date. When you remove the device from your account or delete your account, we clear the owner, upload key, nickname, last IP address and status data.

Signal maps:

We keep signal maps in the library. A published signal map is not linked to you. See Signal maps.
Before we publish a signal map, we keep its link to your bike and device. Otherwise, we delete the link within a day after the period for learning captures in the table above ends. That period counts from when you first submitted the map.
We delete it earlier when we publish the map, when you delete that bike or your account, or remove the device from your account.
When the link ends, the map stays. Deleting a bike or your account, or removing a device from your account, never deletes a signal map.
After the link ends, our staff access record can still show that staff looked at a signal map of yours awaiting review. It does not show which map. We keep it for 12 months.

When you delete a ride:

The ride disappears from the RideTrace app and the dashboard at once. You cannot restore it.
After the period in the table, we delete the ride and everything that belongs to it. That is the timeline, the motion data, the summaries, the findings and the route images. We then update your bike-health results without that ride.
If the ride is still processing, we delete it after processing ends.

When you remove a recording that is not part of a ride:

The recording disappears from the RideTrace app and the dashboard at once. You cannot restore it.
After the same period as for a ride, we delete the recording and everything that belongs to it. That is the timeline, the motion data, the summaries and the findings.

A recording that is part of a ride is deleted with the ride. A recording that is still processing can be removed after processing ends.

When you delete your account:

Deletion takes effect at once. You cannot undo it.
We cancel your subscription at once, with no refund of the remaining paid time. This does not affect your right of withdrawal. See the Terms.
We remove your devices from your account and delete your sign-in account at Clerk.
We then delete your rides, your bikes, your results and your exports. We also delete the data that your devices recorded: logs, crash dumps, status data and learning captures.
We delete your settings, the notifications in your app inbox and the push addresses of your phones.
We keep your orders and withdrawal requests as accounting and contract records. They are no longer linked to your account.
We keep a short record that an account was deleted. It holds the account's internal ID and counts, but no name or email address. We keep it as proof of the deletion.
We keep the records of the emails and notifications that we sent you, or chose not to send, and why. They hold no email address and no push address. They are no longer linked to your account, and we keep them for the rest of their 24 months. The record of the email that confirmed we received a withdrawal stays as long as the withdrawal request.
If an email address bounced or marked our email as spam, we keep it on our list of addresses that we do not send to, until our staff remove it.
For the period in the table, we keep a one-way code made from your account ID. It stops a deleted account from coming back by mistake.

Backup copies:

We make a backup copy of our database and stored files every day. We keep each copy for the period in the table above, then we delete it.
Data that you delete stays in the backup copies that we made before, until we delete those copies. We do not use it.

What deletion cannot reach:

The data on the device and its memory card. Reset the device first. See Data on the device.
Copies that you already have, such as exports that you downloaded.
Stripe's own records of your payments.
Resend's own records of the emails that it sent you. See Emails.
The records that Expo, Apple and Google keep of the phone notifications that they delivered to you. See Inbox and phone notifications.
A notification that your phone already shows. Remove it on the phone.
The dashboard cache at Vercel. We mark your data in it as out of date, so the dashboard never shows it again. Vercel removes it.
The visit statistics at Vercel. They are not linked to your account. See Visit statistics.

When you remove a device from your account, we delete what it recorded for you: its logs, crash dumps, status data and learning captures. Your rides and bikes stay. The device's hardware record stays, without your name or its link to you.

Your rights

You can get a copy of all your data, correct it, export it and delete it. You can delete a ride, remove a recording, or delete your account yourself. For everything else, write to us.

Your right to object (Art. 21). You can object at any time to each use in Why we use your data that relies on a legitimate interest. You can do this for reasons that concern your particular situation. Write to privacy@ridetrace.app. We then stop, unless we show compelling legitimate grounds that override your interests, rights and freedoms, or we need the data for a legal claim.

If you object to the membership reminders, we stop them in every case. The "Stop these reminders" link in each reminder email stops the reminder emails at once. The Membership reminders switch in Settings stops the phone notifications. It is under Phone notifications on the dashboard, and under Notifications in the app. When both are off, the reminders also stop arriving in your app inbox. When you object by writing to us, we turn both off for you.

You can object to tips and milestones, or to how we choose who receives them. Turn off the Tips and milestones switch in Settings, or write to us. They then stop on your phone and in your app inbox.

Under the GDPR, you also have these rights:

Access (Art. 15): you can get a copy of all the personal data that we hold about you, and information about how we use it.
Rectification (Art. 16): you can correct data that is wrong. You can change your bike details yourself.
Erasure (Art. 17): you can ask us to delete your data. You can delete a ride, remove a recording that is not part of a ride, or delete your whole account yourself.
Restriction (Art. 18): you can ask us to stop using your data for a time, for example while we check a correction.
Portability (Art. 20): you can receive the personal data that you provided to us, including data that your device recorded, in a structured, common and machine-readable format. You can also ask us to send it to another controller, where this is technically possible.
Withdrawal of consent (Art. 7(3)): you can withdraw your consent at any time. This does not affect what we did before.

What you can do yourself:

Delete a ride: in the RideTrace app or on the dashboard.
Remove a recording that is not part of a ride: in the RideTrace app or on the dashboard.
Delete your account: in the RideTrace app or on the dashboard. The delete account page tells you how.
Export your data: in the RideTrace app or on the dashboard. You get one ZIP file for your whole account. You can export also when your membership is off.

The export contains:

your profile: email address, name, time zone, the country your phone was set to when you signed up in the app, the date you created your account, and the Terms that you accepted
your bikes, with their VIN
your devices, with their serial numbers
the list of your rides, with times, distance and duration
one GPX file for each ride, made from the GPS positions that the device recorded. Also one GPX file for each recording that is not part of a ride
no GPX file for a recording that you removed

You can make one export in each 24 hours. Download the file soon, because we delete it after the period in the retention table.

For every other request, write to privacy@ridetrace.app. Write from the email address of your account, or, if you have no account, from the email address that you gave us.

We check that the request comes from you before we answer.
We answer within one month. If a request is complex, or if you send many, we can extend this by two further months. We then tell you within the first month.
If we do not act on a request, we tell you why within one month. You can then complain to a data protection authority. See Complaints.
We do not charge you.
People who have no account can use these rights too, for example a guest buyer or a person on the waitlist. They write to privacy@ridetrace.app. We check who they are with data that we already hold, such as the order number or the waitlist email address.
A person who rode your bike, or rode with you as a passenger, can also ask for their data. They tell us the date of the ride and the bike. Their data is in the account of the bike's owner, so we assess the request with the owner's rights in mind.

A copy of your data under Art. 15 contains all the personal data that we hold about you. This includes:

the export
your ride timelines, with the values from your bike and the motion sensor, and your ride summaries
the values that RideTrace derives from your rides, such as your bike-health values
your findings and scores, as a readable list
your device data: status data, logs and crash dumps
your learning captures, while we still keep them
the link between your bike and device and a signal map that we have not published yet
your orders and withdrawal requests
your settings, your app inbox, and the push addresses of your phones
your messages to us
your sign-in data, and the record of the Terms that you accepted
the record of staff access to your data

The copy gives your data. It does not explain how RideTrace computes its results, because that is our trade secret.

Signal maps:

A published signal map is not personal data, so your GDPR rights do not apply to it. See Signal maps.
Before we publish a signal map, its link to your bike and device is personal data. Your rights apply to the link. A copy of your data under Art. 15 includes the link while we keep it.
If you ask us to erase your data (Art. 17), or you object (Art. 21), we delete the link. The map stays in the library.
When you delete your account, we delete your learning captures and the link. Signal maps that other riders installed stay on their devices.

Automated decisions

RideTrace makes no automated decision that has a legal effect on you or that affects you in a similarly significant way.

RideTrace computes scores, coaching and bike-health findings automatically. This is profiling under the GDPR, because it evaluates how you ride.
The results are information for you. They do not decide anything about you.
We do not give your scores or findings to insurers or other third parties. The only exception is a valid order under EU or Romanian law.
We choose who receives tips and milestones, product news and the required notices from facts about your account. This choice decides only which of these messages you get. See Inbox and phone notifications.
Some steps of your contract happen automatically. For example, membership turns off when your membership time ends. These steps follow the rules in the Terms. They do not assess you.

So GDPR Art. 22, on decisions based only on automated processing, does not apply.

Children

RideTrace is only for people aged 18 or older.

You must be 18 or older to use RideTrace. When you accept the Terms or order a device, you confirm that you are 18 or older.
Your account works only after you accept the Terms and confirm that you are 18 or older. If you never do, we delete the account as How long we keep your data describes.
We do not knowingly collect data about children.
If we learn that a person under 18 has an account or a waitlist entry, we delete it.
If you think that a person under 18 uses RideTrace, write to privacy@ridetrace.app.

Security and breaches

We protect your data in transit and control who can see it. The device encrypts its internal memory, but not its memory card. If a breach puts you at high risk, we tell you.

What we do:

Every internet connection to RideTrace is encrypted with TLS. The device checks the certificate of our server.
The Bluetooth connection between the RideTrace app and the device is encrypted by Bluetooth.
You sign in through Clerk. Only authorised staff can open the admin console.
We log staff access to rider data through the admin console.
Each device uploads with its own key. We store only a one-way code of that key.
Rate limits on selected routes protect RideTrace against abuse.
The logs of our API server and our map server do not record your IP address or your sign-in data.
The device installs a software update only if RideTrace signed it. It also checks that the update is complete.
The device encrypts its internal memory. It starts only software that RideTrace signed.
A person can add a new device to an account only with the setup code that comes with the device. Keep the setup code private.
We make a backup copy of our database and stored files every day. We encrypt it on our server before we store it at Cloudflare, in the EU.

What the device does not do yet:

The device does not encrypt its memory card. The card holds your ride files until they sync, your learning files and crash dumps. See Data on the device.
The setup code of a device cannot be changed.

The memory card stays readable, so that you can read your own files.

If a personal data breach happens:

We report it to the ANSPDCP as the GDPR requires.
If the breach is likely to put your rights and freedoms at high risk, we tell you without undue delay.
We tell you what happened, what it can mean for you, what we did about it, what you can do, and whom to contact.

To report a security problem, see our security policy.

Cookies and local storage

We use only the cookies that you need to sign in. On the public pages of our website, we count visits without cookies. We use no advertising, and nothing that follows you across websites.

The dashboard uses only the session cookies of Clerk, our sign-in provider. They keep you signed in. They are strictly necessary, so the law does not require your consent for them (Law 506/2004).
On the public pages of our website, we count visits with Vercel Web Analytics. It sets no cookie, and it stores nothing in your browser. See Visit statistics.
We use no advertising cookies or tools, and nothing that follows you across websites. The RideTrace app contains no analytics, advertising or tracking tools.
The dashboard and the maps load their fonts from our own servers.
We use no cookie that needs your consent, and our visit statistics store nothing in your browser. So our website shows no cookie banner.

The device and the RideTrace app:

The law on storage in your devices (Law 506/2004) also covers the device and your phone.
The device sends us your rides, its status data, its logs and its crash dumps. It installs the software updates that you start.
The RideTrace app stores the data in Data on your phone.
We need each of these to give you the service that you asked for and to keep the device secure. So the law does not require your consent for them.

If we ever add a cookie, or store something in your browser that is not strictly necessary, we will ask for your consent first.

Visit statistics

On the public pages of our website, Vercel counts the visits for us, without cookies. Vercel receives nothing from the pages for signed-in riders, and nothing from the RideTrace app.

Where we count:

We count visits on the public pages of ridetrace.app. Examples are the home page, the waitlist, the shop, the rider manual and these legal pages.
Vercel receives nothing from the pages for signed-in riders: the dashboard, your rides, your account, the page where you accept our Terms, and our admin console.
When you open a public page while you are signed in, Vercel counts the visit like any other. The visit is not linked to your account.

What Vercel receives for each public page that you open:

The address of the page. Before the address leaves your browser, we remove the part after "?" or "#". We keep only the campaign tags that start with "utm_". They show which of our links or campaigns brought you. On the page of an order, we replace the order number with a placeholder.
The address of the page that sent you, if your browser gives it.
Your IP address and your browser's description (the user agent). Your browser sends them with every request. From them, Vercel finds your approximate location, such as the country and the city, your browser, your operating system and your type of device.

The steps that we count:

You open the waitlist form. We also count which button you used.
You join the waitlist. We count it only after Clerk confirms that you joined. We also count which form you used.
You save a "Notify me" request in the shop. We also count whether the request is about stock or about your country.
You start a checkout, just before your browser goes to Stripe. We also count the country of delivery, and whether your bike is in our list.
You come back from Stripe's payment page without paying.
The shop shows your order as paid.

Each step sends only its name, the address of the page and the detail above. No step sends your email address, your name, an order number, an amount or anything from your account.

How Vercel counts:

Your browser gets the counting script from ridetrace.app, and it sends the data to ridetrace.app. Vercel, our web host, receives it there.
Vercel counts a visitor with a code that it makes from the request. It deletes this code after 24 hours. So it does not recognise you on a later day, or on other websites.
The records that Vercel keeps do not hold your IP address.
We see only totals, for example how many visitors opened a page or started a checkout.

Why we count, and what you can do:

We use the totals to see which pages people read, where they come from and where they stop. We use them to improve the website.
The legal basis is our legitimate interest, Art. 6(1)(f). See Why we use your data.
The records are not linked to your account, and they hold no IP address. So we cannot find your visits in them, for example to give you a copy or to delete them.
A content blocker in your browser stops the count. The website works the same without it.
Vercel keeps the records for the period in the retention table.

Product data of the device

This section gives the information that the Data Act asks for about the data that your device generates.

This section gives the information of Art. 3 of the Data Act, Regulation (EU) 2023/2854.

We are a micro-enterprise, with no partner or linked enterprise that is larger. So Chapter II of the Data Act, which includes Art. 3, does not apply to the data that the device generates (Art. 7(1)). We publish the Art. 3 information anyway.

What the device generates:

A ride timeline, with about 5 rows each second. It holds the values from your bike's data network, such as engine speed and gear, and the GPS position with its quality.
Motion samples from the motion sensor, 25 each second.
Ride events and a ride summary.
Device logs and, after a crash, crash dumps.
Learning captures, when you teach RideTrace your bike's signals.

Format: the device writes the data as NDJSON files. NDJSON is plain text, with one JSON record on each line. Crash dumps are binary files (ELF) with a small JSON file. The files are on the microSD memory card in the device.

Volume: a ride makes about 0.58 MB of data for each minute of riding, which is about 35 MB for each hour. About half of this is the timeline and half is the motion data. Device logs add about 43 to 90 KB each time the device starts. A learning session of 10 steps makes about 3.6 MB. We measured these values on rides in September 2026 with device software 1.0.0. The volume can change with the software version and with the signals that your bike makes available.

How the device generates and sends the data:

The device generates data continuously while you ride.
It does not send the data to RideTrace in real time. After the ride, it uploads the files over Wi-Fi.
While the RideTrace app is connected to the device over Bluetooth, the app shows live values from the device about once each second.
During learning, the app sends the learning captures to RideTrace.

Where the data is stored and for how long:

On the device: on the memory card until the files sync to RideTrace. See Data on the device.
On our servers: for the periods in How long we keep your data.
On your phone: the short-lived copy, and the learning captures until RideTrace accepts them. See Data on your phone.

How you can get the data and delete it:

See your rides in the RideTrace app and the dashboard.
Export your data at any time, free of charge. The export holds your GPS positions. The values from your bike and the motion samples are not in the export. See Your rights.
Ask for a copy of all your data by email, including the values from your bike and the motion samples. See Your rights.
Read the NDJSON files on the memory card on a computer. After a file syncs, the device deletes it from the card.
Delete a ride, remove a recording, delete your account, or reset the device. See How long we keep your data and Data on the device.

Who holds the data and what we do with it:

RideTrace holds the data. Our contact details are in Who is responsible.
We use the data for the purposes in Why we use your data.
The recipients are in Who receives your data. See also Signal maps.
How RideTrace computes its results is our trade secret. We do not share it.
The contract, its duration and how to end it are in the Terms.

Complaints

Write to us first if you can. You can always complain to a data protection authority.

If you have a complaint about how we use your data, write to privacy@ridetrace.app.
You have the right to complain to a data protection authority. In Romania, this is the National Supervisory Authority for Personal Data Processing (ANSPDCP): www.dataprotection.ro.
You can also complain to the authority of the EU country where you live, where you work, or where the problem happened.

Changes to this policy

When we change this policy, we change the version and the date. We tell you about an important change before it applies.

When we change this policy, we change its version and the date at the top of this page.
Before an important change, we give you 30 days' notice by email. The RideTrace app and the dashboard also show you the new version when you next use them.
If a change needs your consent, we ask for it first.

Versions:

Version 2, 9 October 2026: this text. It names who is responsible for your data, and lists the data that we collect and why. It names every recipient, and gives the retention periods, your rights, and the product data of the device.
Version 1, June 2026: a short first notice.