1. Who is responsible

This Privacy Policy applies to the Cold Water Therapy mobile and companion watch applications and our website at coldwatertherapy.app. The information processed depends on your platform, device, app version, permissions and the features you use.

LKLK s. r. o. is the controller for the CWT account and service processing described here. Apple, Google and other providers may also act as independent controllers for their own platforms, payments or advertising. Their privacy notices explain those separate activities. Reading or accepting this policy is not, by itself, consent to every type of processing.

2. Information we process

Required account fields are needed to create or authenticate an account and provide account features. Health access, device location, notes and photographs are feature-dependent choices. Notes and photographs can reveal additional personal or health information; include only information you intend to store or share.

3. Why we process information

We use account, programme and session information to provide the features you request: authentication, timers, saved history, summaries, synchronisation, exports, purchases and support. We use optional measurements and location for the functions explained below. Diagnostics help investigate failures, protect service availability and improve reliability. Advertising supports the free version.

Where the EU General Data Protection Regulation applies, account and requested service processing is based on performance of our contract with you, or steps you request before a contract (Article 6(1)(b)). Optional consent-dependent processing is based on consent (Article 6(1)(a)); health information additionally requires an applicable condition under Article 9, including explicit consent where required. Providing the service under a contract does not, by itself, authorise every use of health information.

Necessary security, fraud prevention and fault investigation may be based on our legitimate interests in operating a reliable service (Article 6(1)(f)), balanced against your rights. Legal and accounting obligations use Article 6(1)(c); necessary legal claims may use Article 6(1)(f). These bases do not override requirements for device permissions, sensitive information or consent under applicable law.

You can withdraw consent and exercise the rights explained in section 11. A device permission for one purpose does not authorise advertising, unrelated analytics or other purposes.

4. Health data and watches

What we access and why

Cold Water Therapy uses health and fitness information to show heart rate during a session and provide recorded sessions, average heart rate, charts, summaries and history. Activity type, date, duration, temperatures and information you enter can form part of a health-related session record. These features support personal wellness tracking; CWT does not provide clinical monitoring, diagnose conditions or make medical decisions about you.

Android and Wear OS. On compatible Wear OS watches, CWT reads heart rate directly from the watch sensor. It requests the applicable permission: BODY_SENSORS on supported older Android versions or READ_HEART_RATE on Android 16 and later. This direct sensor feature does not obtain historical records from Google Fit or Health Connect.

In Wear OS version 3.11.19 and later, a separate Health data notice explains the measurements, their use and their transfer to your phone and CWT servers before the app enables heart-rate collection. You can choose to enable heart rate or continue without it. You can reopen this choice through Health data on the watch programme setup screen. Device permission is also required. The timer can operate without heart-rate access.

iPhone and Apple Watch. Where supported and enabled, CWT accesses heart-rate and workout information through Apple Health/HealthKit and can save workouts. Supported watch features request heart rate, active energy, swimming stroke count, swimming distance, water temperature and workouts. Apple Health permissions and the CWT health connection govern the relevant features; a permission request does not mean every session accesses every type.

Where measurements are stored

Session records are stored locally on your devices. Supported synchronisation transfers records between the watch and phone and uploads account session records to the CWT backend. Uploaded fields can include heart-rate samples and averages, date, duration, temperatures, notes, optional location and selected photographs. Health-related session information is therefore not stored exclusively on your watch or phone. Some platform-specific measurements, such as supported Apple Watch swimming distance, can remain in local and watch-to-phone records rather than the server upload.

Health information is used for the requested tracking and record features. We do not sell health information or use heart-rate measurements to select or personalise advertisements or build advertising audiences. Hosting and other necessary service providers process information to operate the service as explained in section 7; this is different from supplying health records for advertising.

Your controls

You can revoke sensor permissions in device settings and change the Wear OS Health data choice. On Apple devices, manage CWT access in Apple Health/device settings and the CWT health connection where available. Turning off the phone's CWT health connection does not itself stop standalone workouts on Apple Watch; manage watch access separately.

Revoking a permission stops future access through that permission. It does not automatically delete existing CWT records or workouts already saved in Apple Health. To request removal of CWT health/session information, use the account deletion page or contact us about particular records or withdrawal of consent. Manage independent Apple Health records separately in Apple Health. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

5. Location and other permissions

• Weather and location. We use permitted device location for local weather and map/place features. Weather requests may send coordinates to the weather provider even when saving a session's location is switched off. The CWT location-saving setting controls attaching a location to the record; revoke the operating-system location permission to stop further device-location access.
• Photographs. When you choose a profile or session photo, the selected image can be stored locally and uploaded with the account or session. Camera/photo access and available selection tools depend on your operating system.
• Notifications, alarms and Live Activities. These support the timers and session features you enable. On supported Apple devices, activity/push tokens, account/session identifiers and activity timing information can pass through the CWT backend and Apple's notification services. Lock-screen and watch displays may be visible to people nearby.
• Companion connection and local storage. These support communication with a watch, settings, saved records and pending synchronisation. An offline device may keep its own local copy until it reconnects or you remove it.
• Exports and sharing. Exporting or sharing creates a copy at a destination you choose. That destination and its recipients control the copy under their own rules.

Previously saved information is not automatically erased when you switch off a permission. Permission names and settings vary by device and system. Declining Apple's tracking permission controls access such as the IDFA; it does not replace separate choices for health, location or other processing.

6. Advertising, analytics and diagnostics

Advertising. The free app uses Google AdMob. Depending on your choices and applicable law, Google and the ad technology providers identified in the consent message may process device/ad identifiers, IP address, general location and ad delivery/interaction information. Google UMP presents the applicable advertising privacy choices. Review the purposes and provider list in that message and use advertising privacy options in the app where available to change your choices. Non-personalised advertising can still involve technical information and device storage.

Premium removes in-app advertising while the entitlement is active. It does not automatically disable account processing, crash diagnostics or every analytics service.

Usage analytics. CWT uses Firebase/Google Analytics to understand app navigation and usage. Android records screen/navigation events. The app-defined screen events use screen names rather than the contents of your notes, photographs, heart-rate measurements or precise location. In supported iOS versions, the Usage Analytics choice controls optional UI analytics. Choices and controls differ by platform and version; a choice made on one device does not automatically apply to another device or to the website.

Crash diagnostics and bug reports. Firebase Crashlytics processes crash traces, device/OS/app details, timestamps, installation identifiers and error context to help investigate failures. Crash diagnostics are separate from optional usage analytics. A bug report you deliberately send can contain your message and diagnostic attachments. Do not include passwords or unnecessary health information. You can contact us about diagnostic processing and exercise the rights in section 11.

See Google's Privacy Policy, how Google uses information from apps using its services and Firebase privacy information.

7. Service providers and other recipients

Information processed on our behalf is limited to the relevant service purpose. Some providers also act as independent controllers for their platform or advertising activities. We do not sell your session records. The use of hosting, platform and diagnostic services means that some information is disclosed to service providers; the service is not exclusively device-local.

8. International processing

CWT backend hosting, database and photo storage with Websupport are located within the European Union. Our email-delivery and support processing is based in Slovakia. Your email provider may process its own copies in other countries.

Apple, Google/Firebase, advertising and weather services operate internationally. Their processing can take place outside the European Economic Area, including in the United States. EU backend hosting does not mean that every external service processes information only in the EU.

Where a transfer is subject to restrictions under data-protection law, it requires an applicable legal basis and transfer safeguards, such as an adequacy decision or appropriate contractual safeguards. The arrangements depend on the provider and processing involved. Contact info@coldwatertherapy.app for information about the safeguards relevant to your data and how to obtain the relevant information.

9. Retention and security

We retain information for the purpose for which it is needed, taking account of the account and records you keep, deletion or consent requests, backup rotation and specific legal requirements. Account deactivation does not, by itself, justify indefinite retention of identifiable records.

Deletion from CWT does not itself remove copies held independently on offline devices, records in Apple Health, files you exported/shared or store records controlled by Apple or Google. We explain any specific lawful reason for retaining information when handling your request.

Provider information: Firebase privacy and retention, Google Analytics retention and Websupport database backups.

CWT backend connections and the public deletion-request page use HTTPS. Support verifies account ownership and confirms the request before permanent erasure; if the account email is inaccessible, proportionate alternative verification may be needed. Protect access to your device and email account. No internet transmission or storage system can guarantee absolute security; contact us if you suspect unauthorised access.

10. Delete your account and data

1. Email info@coldwatertherapy.app with the subject CWT account and data deletion. State that you want your account and all associated data permanently deleted and identify the email used for your CWT account. If possible, send the request from that address.
2. Support verifies account ownership and confirms your request with you before permanent deletion. If you used Sign in with Apple, your CWT email may be an Apple private relay address. Explain if you cannot receive messages at the account address so that proportionate alternative verification can be arranged. Do not send passwords, PINs, full payment-card details or unnecessary health measurements.
3. The request covers the verified account and its associated CWT session records, including recorded health measurements, notes, uploaded profile/session photographs, associated in-database working copies and applicable CWT server purchase, live-activity or push-token records, subject to the specific lawful-retention exceptions in section 9.
4. Support also checks relevant CWT-specific sign-in records held in Firebase and required photograph cleanup. A request is not described as completed while required cleanup remains unresolved. This concerns records held for CWT; it does not delete your personal Apple or Google account.
5. Support confirms the outcome by email. Opening the webpage or an email draft does not submit or complete a deletion request: you must send the message. An acknowledgement only confirms receipt.

In Android version 3.11.19, Profile → Delete Account opens the webpage above. Follow the instructions on that page to submit your request to support. In iOS version 3.13.12, the existing in-app Delete Account action deactivates the server account and clears local app information; it does not by itself permanently erase the server records. Older app versions can also offer a deactivation-only action. To request complete erasure from any version, use the webpage or email above.

You can also request deletion of particular records without deleting the whole account: identify that request in your email. If the account email is inaccessible, provide your CWT username or account identifier if known and explain the access problem. Support may need proportionate information to verify ownership.

Support handles verified requests without undue delay. Where the GDPR applies, we normally respond within one month of receiving the request; if a legally permitted extension is necessary because of the complexity or number of requests, we explain it within the first month. This is a response deadline, not a claim of automatic instant deletion or a promise that every independent platform or backup copy has the same deletion timetable.

Minimum information may need to be retained for a specific lawful obligation, security purpose or legal claim. Such retention is limited to that reason and is explained as appropriate. Backup and provider-held information follows the separate processes described in section 9.

Account deletion does not automatically cancel an Apple App Store or Google Play subscription. Manage renewal separately in your store account. Cancelling a subscription or buying Premium is not a condition for submitting an erasure request. Manage Apple Health records and exported/shared copies separately with the relevant device or recipient.

11. Your rights and choices

Subject to applicable law and relevant exceptions, you can request access and a copy of your information, correction, erasure, restriction and portability of information processed by automated means on the basis of consent or contract. You can withdraw consent at any time, object to processing based on legitimate interests and object to direct marketing. Contact info@coldwatertherapy.app; Premium is not required to exercise these rights.

Requests are normally free. A lawful fee or refusal for a manifestly unfounded or excessive request applies only where the law permits it and with an explanation. CWT does not make solely automated decisions producing legal or similarly significant effects about you. Session totals and summaries are informational calculations, not clinical assessments.

You can complain to a supervisory authority, including in your place of habitual residence, work or the alleged infringement. In Slovakia, contact the Úrad na ochranu osobných údajov Slovenskej republiky at dataprotection.gov.sk for current contact details and complaint instructions. You do not have to contact us first to complain.

12. Website, younger users and updates

Website. Our WordPress website's delivery and security involve technical requests to the hosting service, which can include IP address, timestamp, requested page and browser information. We use information submitted by email or contact form to answer you. Website analytics, cookies and embedded services can process browser/device identifiers, visits, interactions and approximate location. Non-essential cookies or similar storage require consent where applicable law requires it. Browser settings and any website consent controls apply separately from choices in the mobile app.

Younger users. CWT is intended for adults aged 18 or over. People under 18 must not create an account or use the service. If you believe an under-18 user has provided personal information, contact us so that we can investigate and arrange appropriate restriction and deletion. This eligibility rule is not a claim that every user's age is automatically verified; a store age rating does not establish medical suitability for cold exposure.

Updates. We revise this page when relevant practices change and give additional notice of material changes where required. A revised policy does not by itself authorise an incompatible new use of existing information. We obtain additional consent where required before beginning consent-dependent processing.