nikita-bak

TrackMate Privacy Policy

Last updated: 09 May 2026

This Privacy Policy explains how TrackMate collects, uses, stores, discloses, and otherwise processes personal data when you use the TrackMate mobile application and related services (together, the “Service”).

TrackMate is developed and operated by Nikita Baklanov, an independent developer based in Germany (“TrackMate”, “I”, “me”, or “my”). For the purposes of the General Data Protection Regulation (“GDPR”) and similar laws, I am the controller of the personal data described in this Privacy Policy unless this Policy states otherwise.

1. Scope

This Privacy Policy applies to:

• the TrackMate mobile app;
• subscriptions and paid features offered through the app;
• support, account, and subscription communications related to the Service; and
• AI-assisted features, analytics, and diagnostics used as part of the Service.

This Privacy Policy does not replace the privacy practices of Apple, Google, your authentication provider, or other third-party platforms that you use separately from TrackMate. Those third parties process personal data under their own terms and privacy notices.

2. Personal data I collect

Depending on how you use TrackMate, I may collect the following categories of personal data.

2.1 Data you provide directly

• Account and profile data. Name, email address, authentication provider details, profile settings, and internal account identifiers.
• Garage and vehicle data. Vehicle make, model, year, horsepower, drivetrain, tire details, setup information, and similar information that you choose to add.
• Session notes and support content. Notes, feedback, support requests, attachments, and other content you submit.
• Preferences. Language, units, skill level, onboarding responses, and app settings.

2.2 Data collected when you use the Service

• Location and session data. GPS coordinates, route data, track and layout selections, lap and sector times, session duration, distance, speed, and related driving-session information.
• Telemetry and sensor data. Device sensor readings and derived metrics, including acceleration, gyroscope data, braking or cornering signals, and performance analysis generated from those signals.
• Weather and contextual data. Weather conditions, precipitation risk, temperature, and related session context when weather features are used.
• Device, app, and diagnostic data. Device model, operating system, app version, IP address or similar network information, crash reports, logs, performance diagnostics, and security or abuse-prevention signals.

2.3 Subscription and purchase data

If you purchase, restore, or use TrackMate - Race Engineer Pro, I may process:

• TrackMate account identifiers and subscription-related identifiers such as a RevenueCat app user ID;
• product identifiers, entitlement identifiers, subscription status, purchase or renewal events, expiration dates, billing-status information, and store environment details; and
• store transaction metadata such as original transaction identifiers and RevenueCat webhook event identifiers.

Payments are processed by Apple App Store or Google Play. I do not receive or store full payment card numbers, bank account details, or app store passwords.

2.4 AI feature data

When you use AI-assisted features such as Race Engineer feedback, debriefs, summaries, or similar features, I may process relevant session, telemetry, vehicle, track, support, and contextual data needed to generate the requested output.

2.5 Data that may be treated as sensitive under some laws

Depending on the law that applies to you, some of the data above may be considered sensitive personal data, including:

• precise geolocation or route history; and
• telemetry or performance data that may reveal detailed behavior patterns.

TrackMate does not use this data to infer health status, race or ethnicity, religion, sexual orientation, or other special-category characteristics.

3. Sources of personal data

I collect personal data from the following sources:

• directly from you when you create an account, configure the app, contact support, or submit content;
• automatically from your device and the app when you record sessions or use features;
• from Apple App Store or Google Play in connection with purchases, subscription renewals, billing events, refunds, and cancellations;
• from RevenueCat for subscription verification, entitlement management, restore flows, and purchase event processing;
• from authentication or sign-in providers that you choose to use;
• from weather, mapping, hosting, crash-reporting, notification, and infrastructure providers that support the Service; and
• from other users or organizations only if they lawfully share data with you through the Service.

4. How I use personal data

I use personal data to:

• create and manage accounts;
• record, store, sync, display, and analyze driving sessions;
• provide telemetry analysis, AI-assisted feedback, debriefs, voice feedback, and related insights;
• operate, host, maintain, troubleshoot, and secure the Service;
• process subscriptions, verify purchases, restore entitlements, and prevent payment abuse or fraud;
• provide customer support and respond to requests;
• improve reliability, usability, feature quality, and safety messaging;
• comply with legal, accounting, tax, consumer-protection, and app-store obligations; and
• establish, exercise, or defend legal claims and enforce the Terms of Use.

5. Legal bases for processing

Where the GDPR or similar laws apply, I rely on the following legal bases:

• Performance of a contract. To create your account, provide the Service, record sessions, sync data, provide paid features, and process support requests related to your account or subscription.
• Consent. For optional permissions or processing that require consent, such as location access, push notifications, or any optional marketing communication if I ever offer it.
• Legitimate interests. To secure the Service, prevent abuse, maintain reliability, troubleshoot issues, improve features, and communicate necessary product or account updates, provided those interests are not overridden by your rights.
• Legal obligation. To comply with tax, accounting, fraud-prevention, consumer-protection, law-enforcement, or other legal requirements.

If I rely on legitimate interests, you may object to that processing in some circumstances. See Section 11 below.

6. AI-assisted features

If you use AI-assisted features:

• I may send relevant prompts, session data, telemetry, support text, and contextual data to third-party AI or model-infrastructure providers acting on my behalf or under their own service terms, depending on the configuration used for the feature.
• I aim to minimize the amount of data sent and to send only the data reasonably necessary to generate the requested output.
• AI-generated output may be incomplete, inaccurate, or inappropriate and should be treated as assistive information only.
• TrackMate does not use AI output as the sole basis for decisions that produce legal or similarly significant effects concerning you within the meaning of Article 22 GDPR.

7. Disclosure of personal data

I do not sell your personal data and I do not share personal data for cross-context behavioral advertising.

I may disclose personal data to the following categories of recipients when reasonably necessary to operate the Service:

• Hosting, database, storage, and authentication providers, including Supabase.
• Subscription and purchase management providers, including RevenueCat.
• Platform operators, including Apple App Store and Google Play.
• Notification, delivery, and app infrastructure providers, including Expo and related service providers.
• Crash reporting, monitoring, and diagnostics providers, including Sentry.
• Weather, mapping, analytics, voice, or AI service providers used to power requested features.
• Professional advisers, insurers, auditors, or authorities where reasonably necessary for legal, compliance, or security purposes.
• A buyer, successor, or transaction counterparty in connection with a merger, financing, sale of assets, reorganization, or similar corporate transaction.

I may also disclose personal data:

• if required by law, subpoena, court order, or regulatory request;
• to investigate, prevent, or address fraud, abuse, security issues, or illegal activity; or
• to protect the rights, property, safety, or legal interests of TrackMate, users, or others.

8. International data transfers

Some service providers may process personal data outside your country of residence, including outside the European Economic Area, the United Kingdom, or Switzerland.

Where required by applicable law, I use a lawful transfer mechanism such as:

• an adequacy decision;
• the European Commission’s Standard Contractual Clauses or equivalent safeguards; or
• another lawful derogation or safeguard recognized by applicable law.

You may contact me if you want more information about the safeguards used for a specific transfer.

9. Data retention

I keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Service, comply with legal obligations, resolve disputes, and protect against fraud or abuse.

Retention depends on the category of data:

• Account and profile data. Kept while your account is active and for a limited period afterward as needed to complete deletion requests, resolve support issues, prevent fraud, or comply with legal obligations.
• Garage, session, telemetry, notes, and preference data. Kept until you delete the data, delete your account, or request deletion, unless a longer period is reasonably necessary for backup integrity, security investigations, dispute handling, or legal compliance.
• Subscription and transaction data. Kept for as long as needed to manage subscription access, maintain audit trails, prevent fraud, and satisfy accounting, tax, chargeback, refund, and recordkeeping obligations.
• Support communications. Kept for as long as needed to respond to the issue, improve support quality, keep a record of the request, or protect against legal claims.
• Crash reports, logs, and diagnostics. Kept for a limited operational period and longer only if reasonably necessary to investigate a reliability, security, or legal issue.

Backups and cached copies may remain for a limited additional period until they are overwritten in the ordinary backup or deletion cycle.

10. Security

I use reasonable technical and organizational measures designed to protect personal data, including authenticated access controls, encrypted transmission where supported, environment-based access restrictions, and third-party infrastructure security controls.

No service or transmission method is completely secure. I cannot guarantee absolute security.

11. Your privacy rights

Depending on where you live, you may have rights under applicable law, including the right to:

• access personal data;
• correct inaccurate personal data;
• request deletion of personal data;
• receive a portable copy of certain personal data;
• object to certain processing, including some processing based on legitimate interests;
• request restriction of certain processing;
• withdraw consent at any time where processing is based on consent; and
• lodge a complaint with a supervisory authority or regulator.

You may also have rights under applicable US state privacy laws, such as the right to know, delete, correct, and appeal a denied request where those laws apply.

To exercise your rights, contact me using the details in Section 16. I may ask for reasonable information to verify your identity before completing your request. Where GDPR applies, I generally aim to respond within one month, subject to lawful extensions.

12. Account deletion and app deletion

• Deleting the app from your device does not delete your TrackMate account.
• Deleting your TrackMate account does not automatically cancel a subscription purchased through Apple App Store or Google Play.
• You must manage or cancel app-store subscriptions through the relevant store settings unless applicable law requires another option.

13. California privacy information

This section is intended to help California residents understand TrackMate’s practices. It is provided for transparency. Certain rights described here apply only if the California Consumer Privacy Act, as amended by the CPRA (“CCPA/CPRA”), applies to TrackMate.

In the preceding 12 months, TrackMate has collected the following categories of personal information as described in this Privacy Policy:

• identifiers and contact information;
• account information;
• commercial or subscription information;
• internet or network activity and device information;
• geolocation data;
• sensory or telemetry-derived information;
• inferences or analytics derived from session data; and
• user-submitted content and support communications.

TrackMate may also collect sensitive personal information, such as precise geolocation, but does not use or disclose sensitive personal information for purposes other than providing the requested services, maintaining security, preventing fraud, or other purposes permitted by law.

In the preceding 12 months:

• TrackMate has not sold personal information.
• TrackMate has not shared personal information for cross-context behavioral advertising.
• TrackMate may have disclosed personal information to service providers or contractors for business purposes described in this Privacy Policy.

If the CCPA/CPRA applies to TrackMate, California residents may request access to, correction of, or deletion of personal information and may request information about categories of personal information collected, sources, purposes, and disclosures. To make a request, email me using the contact details below.

14. Children’s privacy

TrackMate is not directed to children under 16. I do not knowingly collect personal data from children under 16. If you believe a child has provided personal data in violation of this Policy, contact me so I can investigate and take appropriate action.

15. Changes to this Privacy Policy

I may update this Privacy Policy from time to time to reflect changes in the Service, legal requirements, or data practices. If a change is material, I will take reasonable steps to notify users before or when the updated Policy becomes effective.

16. Contact

If you have questions, requests, or complaints about this Privacy Policy or TrackMate’s privacy practices, contact:

Nikita Baklanov
E-mail: info@trackmate-race-engineer.com
Germany