Privacy Policy

At Camino ("we," "our," or "us"), we are deeply committed to protecting your personal data and upholding your fundamental rights to privacy and data self-determination. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our mobile applications on Apple iOS (via Apple HealthKit) and Google Android (package: camino.app, via Google Health Connect and Strava API), as well as our official web portal (caminoapp.dk).

This policy is formulated in strict accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Danish Data Protection Act (Databeskyttelsesloven, Act No. 502 of 23 May 2018), the Danish Cookie Executive Order (Cookiebekendtgørelsen),Apple App Store Review Guideline 5.1.1, andGoogle Play Developer Policies & Data Safety requirements.

1. Data Controller Identity & Contact

Under GDPR Article 4(7), the Data Controller responsible for the processing of your personal data is:

2. Categories of Personal Data We Collect

We process only the minimum necessary data required to deliver Camino's gamified fitness platform:

3. Legal Bases for Processing (GDPR Articles 6 & 9)

Under European data protection law, we process your personal data only when an authorized legal basis applies:

• Performance of a Contract (GDPR Art. 6(1)(b)): Processing necessary to create your account, calculate rewards, maintain your coin wallet, issue merchant redemption codes, and operate the Camino service in accordance with our Terms of Service.
• Explicit Consent (GDPR Art. 6(1)(a) & Art. 9(2)(a)): Required before accessing health, motion sensor, or activity data via Apple HealthKit or Android Health Connect, or before linking your Strava account via OAuth. You have the statutory right to withdraw your consent at any time via your device settings or the in-app Strava disconnect toggle.
• Legitimate Interests (GDPR Art. 6(1)(f)): Processing necessary for our legitimate business interests in safeguarding system security, preventing algorithmic spoofing, botting, or fraudulent step manipulation, and diagnosing fatal software crashes.
• Compliance with Legal Obligations (GDPR Art. 6(1)(c)): Retaining transaction or dispute audit logs where mandated by Danish statutory law (e.g. the Danish Bookkeeping Act, Bogføringsloven).

4. Apple HealthKit, Health Connect & Strava Compliance

Apple HealthKit Disclosure (Apple Review Guideline 5.1.1)

Camino uses Apple HealthKit APIs on iOS devices solely to read daily step counts, cycling distance, and cycling workouts (their type and start and end times):

• We do not use HealthKit data for marketing, advertising, or data-broker profiling.
• We do not disclose HealthKit data to third parties without your explicit consent.
• HealthKit data is processed on-device and synced to our secure database only as aggregated daily totals linked to your account UID.

Google Play Health Connect & Sensor Policy

Camino requests the following explicit runtime permissions on Android:

• android.permission.health.READ_STEPS (Steps): your daily step total, to award walking coins and keep your streak.
• android.permission.health.READ_EXERCISE (Exercise sessions): only cycling sessions, outdoors and on an indoor bike, and only their type and start and end times. They identify which distance was ridden, and an indoor ride that records no distance is credited by its riding time. Other workout types are ignored, and no exercise routes, cadence or other session data are read.
• android.permission.health.READ_DISTANCE (Distance): only the distance recorded during those cycling sessions, to award cycling coins. Distance outside a cycling session is not used.
• ACTIVITY_RECOGNITION (not a Health Connect permission): to read the phone's own step counter while the app is open.

Camino only reads from Health Connect and never writes to it. It does not request heart rate, sleep, exercise routes or any other Health Connect data type. The same explanation is shown in the app when Health Connect asks you for these permissions.

In compliance with Google Play's Health Connect policy, health data is never transferred to third parties except as strictly necessary to operate the user-facing rewards platform.

Strava Integration & Anti-Double-Counting

If you voluntarily link your Strava account, our server receives read-only access to your public cycling activities. Our Cloud Functions automatically cross-reference Strava activity timestamps with Apple Health / Health Connect walking intervals to credit your effort accurately and avoid duplicate rewards for the same time window. You can disconnect your Strava account at any time in Settings.

5. Third-Party Processors & Data Hosting

We engage trusted service providers who act as data processors under binding Data Processing Agreements (DPAs) compliant with GDPR Article 28:

6. International Data Transfers

Camino prioritizes storing and processing personal data within the European Economic Area (EEA). Where data is processed by subprocessors outside the EEA (such as the United States), transfers are executed under European Commission Standard Contractual Clauses (SCCs) pursuant to GDPR Article 46, or on the basis of adequacy decisions under GDPR Article 45 (including the EU-U.S. Data Privacy Framework).

7. Data Retention & Automated Deletion

• Active Accounts: Account profiles and aggregate reward histories are retained for as long as your account remains active.
• Account Deletion: When you delete your account in the app, your sign-in account is removed straight away and our servers then automatically erase your profile, daily step and cycling history, coin balance and history, streaks, friend links, leaderboard entries, tournament participation, device notification tokens and any Strava connection (which we also revoke at Strava), normally within minutes. Requests sent by email through our account deletion page are completed within 30 days (GDPR Art. 12). See that page for the full list and for the limited records we keep.
• What we keep after deletion: voucher codes you claimed stay marked as used, so a merchant code is never issued twice, but are no longer linked to you; anonymous totals such as vote counts for suggested places are kept. Deleted data can remain in Google Cloud's encrypted infrastructure backups until those backups expire on their normal schedule.
• Inactive Accounts: We do not currently delete accounts automatically for inactivity. If we introduce an inactivity rule, we will update this policy and notify you before it applies to you.

8. Your Rights as a Data Subject (GDPR Articles 15–22)

Under European and Danish data protection law, you hold the following non-waivable rights:

• Right of Access (Art. 15): Request confirmation and a copy of all personal data we hold about you.
• Right to Rectification (Art. 16): Correct inaccurate or incomplete profile information.
• Right to Erasure ("Right to be Forgotten", Art. 17): Request permanent erasure of your account and all associated activity records.
• Right to Restriction of Processing (Art. 18): Restrict processing during dispute investigations.
• Right to Data Portability (Art. 20): Receive your personal data in a structured, commonly used, machine-readable format (JSON/CSV).
• Right to Object (Art. 21): Object to processing based on legitimate interests.
• Right to Withdraw Consent (Art. 7(3)): Revoke health data or Strava access at any time without affecting prior lawful processing.

To exercise any of these rights, contact us at admin@caminoapp.dkor initiate account erasure directly at caminoapp.dk/delete-account. We respond to all verified requests within 30 days without charge.

9. Right to Lodge a Complaint with Datatilsynet

If you believe our processing of your personal data infringes GDPR or the Danish Data Protection Act, you have the statutory right under GDPR Article 77 to lodge a formal complaint with the Danish Data Protection Authority (Datatilsynet), which acts as our lead supervisory authority:

10. Updates to This Privacy Policy

We may periodically update this Privacy Policy to reflect app enhancements, new integrations, or changes in European regulatory requirements. When significant revisions are published, we will provide conspicuous notice within the mobile application and update the effective date at the top of this document.

11. Contact & Privacy Officer

For any questions, data requests, or privacy concerns, please contact:

Camino Data Protection Team
Email: admin@caminoapp.dk
Camino, CVR 46779002 · Askevænget 9, 2. th, 2830 Virum, Denmark
Web Support: caminoapp.dk/support