Aquatime Privacy Policy

Effective Date: February 6, 2026
App: Aquatime (iOS 26+)
Developer and Data Controller: Fortis AI GmbH
Contact: developer@lammer.ai

1. Data Controller and Contact Information

The controller responsible for data processing within the meaning of the General Data Protection Regulation (GDPR) and other national data protection laws of member states as well as other data protection regulations is:

2. Scope and Application

This Privacy Policy describes how Aquatime processes information when you install and use the iOS application. It applies to all app features, including:

• Time conversion and performance calculations
• Race planning and split analysis (Race IQ)
• Analytics, competitor analysis, and progress reports
• In-app subscription purchases

3. Data We Process

3.1 Data You Provide (Stored Locally on Your Device)

The following data is stored exclusively on your device using Apple's secure storage mechanisms (SwiftData and UserDefaults). This data is never transmitted to our servers.

Profile Information

• First name and last name (optional)
• Birth year
• Gender
• Swimming club or organization name (optional)
• User type selection (swimmer or parent)

Swimming Performance Data

• Swim times (time value, stroke type, distance, pool size)
• Competition dates and names
• Personal best markers
• Calculated metrics (FINA points, Rudolph points, age group)

Race Planning Data

• Race strategies and split targets
• Competitor names and times (entered by you)
• Race history (last 20 race plans)

Multi-Profile Data (Pro subscription)

• Additional swimmer profiles (names, birth years, gender)
• Individual performance data per profile

3.2 Data Retrieved from External Sources

When you explicitly request it, Aquatime retrieves publicly available swimming results from third-party websites. This is a read-only operation; we do not send your personal data to these services.

Austrian Swimming Federation (OSV) Database

• URL: ergebnisse.schwimmverband.at
• Data Retrieved: Publicly published swimmer names, club affiliations, competition results, and official times
• Purpose: Import your official swimming times into the app
• Caching: Results cached locally for 24 hours to reduce network requests

Important: When accessing this external website, standard network metadata (IP address, user agent) is transmitted as required for internet communication. This data is processed by the website operator according to their privacy policy. We do not control and are not responsible for their data processing practices.

3.3 Subscription and Payment Data

Aquatime offers optional subscription purchases processed entirely by Apple through StoreKit 2. We do not process, store, or have access to:

• Credit card or payment details
• Apple ID or account information
• Billing address

We store only the following locally on your device:

• Current subscription tier (Free or Pro)
• Subscription status (active, expired, in grace period)
• Billing period (monthly or annual)
• Expiration date

Apple processes subscription payments according to their Privacy Policy.

3.4 Data We Do Not Collect

• No precise location data or GPS coordinates
• No contacts or address book access
• No health data from HealthKit
• No biometric data
• No advertising identifiers (IDFA)
• No cross-app or cross-site tracking
• No usage analytics or telemetry
• No crash reports via third-party services
• No microphone or camera access

4. Purposes and Legal Bases for Processing

We process your data based on the following legal grounds under Article 6(1) GDPR:

Purpose	Legal Basis	Description
Core App Functionality	Art. 6(1)(b) GDPR - Contract Performance	Processing necessary to provide the app's features: time conversion, performance tracking, race planning
External Data Retrieval	Art. 6(1)(f) GDPR - Legitimate Interest	Fetching publicly available swimming results from OSV to enable performance tracking features
Subscription Management	Art. 6(1)(b) GDPR - Contract Performance	Processing subscription status to provide access to premium features

5. Data Storage and Retention

5.1 Local Storage

All app data is stored exclusively on your device:

• SwiftData Database: Profile information, swim times, swimmers, performance data
• UserDefaults: Preferences, race history, cached settings

5.2 Retention Period

Data remains on your device until:

• You delete it manually within the app
• You uninstall the application
• You reset your device

We do not retain any copies of your data because we do not receive it.

5.3 iCloud Backup

If you have iCloud Backup enabled on your device, app data may be included in your device backup. This is controlled by your iOS settings. Apple processes iCloud data according to their Privacy Policy.

6. Device Permissions

Aquatime does not require any special device permissions. The app functions entirely with locally stored data and does not access your camera, microphone, photos, contacts, location, or other sensitive device features.

7. Third Parties and Data Transfers

7.1 No Data Sharing

We do not share, sell, rent, or disclose your personal data to third parties. We do not operate backend servers and therefore cannot access your app data.

7.2 Third-Party Services

Apple (StoreKit)

Subscription purchases are processed by Apple. Apple acts as an independent data controller for payment processing. See Apple's Privacy Policy.

Austrian Swimming Federation Website

When you request data import, the app connects to ergebnisse.schwimmverband.at. Standard network metadata is transmitted. We do not control their data processing.

7.3 International Data Transfers

Your personal data stored in the app never leaves your device and is not transferred to our servers. When accessing external websites (OSV), data is processed on their servers within the EU/EEA.

8. Data Security

Your data benefits from iOS security features:

• App Sandboxing: Data is isolated from other apps
• File System Encryption: Data encrypted at rest when device is locked
• Secure Enclave: Sensitive operations protected by hardware security

We recommend enabling a device passcode or biometric authentication (Face ID/Touch ID) and keeping iOS updated.

9. Your Rights Under GDPR

Under the General Data Protection Regulation, you have the following rights:

9.1 Right of Access (Art. 15 GDPR)

You have the right to obtain information about whether we process your personal data. Since all data is stored locally on your device and we do not receive or store it, you can access your data directly within the app.

9.2 Right to Rectification (Art. 16 GDPR)

You can correct any data directly within the app by editing your profile, swim times, or other information.

9.3 Right to Erasure (Art. 17 GDPR)

You can delete your data at any time:

• Delete individual items (times, profiles) within the app
• Uninstall the app to remove all app data

9.4 Right to Restriction of Processing (Art. 18 GDPR)

You can restrict processing by revoking permissions in iOS Settings or by not using specific features.

9.5 Right to Data Portability (Art. 20 GDPR)

Your data is stored on your device and included in iOS backups if enabled. You control your data directly.

9.6 Right to Object (Art. 21 GDPR)

You can object to processing based on legitimate interests by discontinuing use of the relevant features or uninstalling the app.

9.7 Right to Withdraw Consent (Art. 7(3) GDPR)

You can withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

9.8 Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority. For Austria:

10. Voluntary Provision of Data

Providing personal data to Aquatime is entirely voluntary. You can use most app features without providing any personal information:

• Name and birth year: Optional. If not provided, personalized features like OSV data import may be limited, but core functionality remains available.

There are no legal or contractual consequences for not providing personal data. The only practical consequence is that features requiring that data will be unavailable.

11. Children's Privacy

Aquatime may be used by swimmers of various ages for legitimate sports performance tracking. The app does not require user accounts, does not collect data remotely, and stores all information locally on the device.

Parents and guardians can manage and review any data entered into the app at any time. If you have concerns about publicly available competition results retrieved from external swimming databases, please consult the privacy policy of the Austrian Swimming Federation.

Under Austrian law, children aged 14 and older may consent to data processing for information society services (Section 4(4) DSG). For children under 14, parental consent is required for any processing beyond what is necessary for contract performance.

12. App Store Privacy Disclosures

In accordance with Apple's App Store requirements:

• Data Collected: None transmitted to developer
• Data Used to Track You: None
• Data Linked to You: None (all data remains on device)

13. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to the app or legal requirements. Updates will be indicated by a revised "Effective Date" at the top of this document. Material changes will be communicated through the app or App Store listing.

We encourage you to review this Privacy Policy periodically.

14. Contact Us

For questions, concerns, or to exercise your data protection rights, contact us:

We will respond to your inquiry within 30 days as required by GDPR.