Privacy Policy

Last updated: September 19, 2026

1. About this Privacy Policy

This Privacy Policy explains how Digital Rebels GmbH, operating under the name Fitrockr (“Fitrockr”, “we”, “us” or “our”), processes personal data when you use Fitrockr websites, applications, APIs, platforms and related services.

Fitrockr provides a wearable and health-data platform that may be used for, among other purposes:

• healthcare and patient monitoring;

• research and clinical trials;

• fitness and wellness programs;

• coaching;

• employee and workplace safety programs;

• insurance programs;

• elderly care and assisted living;

• defense and other specialized programs;

• surveys, ePROs, eCOAs and electronic assessments;

• wearable-data integration and APIs;

• data analytics and reporting;

• health and fitness assessments;

• monitoring, alerting and risk prediction.

Because Fitrockr may process different categories of information for different customers and use cases, the exact processing activities applicable to you depend on the Fitrockr product, project and configuration you use.

This Privacy Policy should therefore be read together with any project-specific privacy notice, consent form, participant information sheet, customer agreement, data processing agreement or other privacy information provided to you.

Where another organization, such as a hospital, research institution, employer, insurer, coach or other customer, determines the purposes and means of processing your personal data and uses Fitrockr to process that data on its behalf, that organization may be the controller of your personal data and Fitrockr may act as its processor. In those circumstances, the organization’s privacy notice and instructions also apply.

2. Who is responsible for your personal data?

The legal entity responsible for Fitrockr is:
Digital Rebels GmbH
Friedrichstr. 155
10117 Berlin
Germany
Email: support@fitrockr.com
Where Digital Rebels GmbH determines the purposes and means of processing, Digital Rebels GmbH is the data controller.
Where Digital Rebels GmbH processes personal data solely on behalf of a customer, Digital Rebels GmbH generally acts as a processor or service provider, as applicable.
For a particular project, the identity of the controller may therefore be different from Digital Rebels GmbH. If you participate in a research study, clinical trial, healthcare program, corporate wellness program, insurance program or similar project, please refer to the privacy information provided by the organization that invited you to participate.
 

3. What personal data do we process?3. What personal data do we process?

Depending on the Fitrockr product, integration, project configuration and permissions granted to us, we may process the following categories of personal data.

3.1 Identification and contact information

This may include:

• first and last name;

• email address;

• username;

• profile photograph;

• country;

• language;

• time zone;

• customer or participant identifier.

3.2 Account and authentication information

This may include:

• account credentials;

• authentication information;

• account status;

• roles and permissions;

• organization affiliation;

• login information;

• security and authentication logs.

Passwords are stored using appropriate security mechanisms and are not stored in plain text.

3.3 Demographic and profile information

Depending on the configuration, this may include:

• year or date of birth;

• age;

• gender or sex;

• height;

• weight;

• country;

• other profile information provided by you or the organization operating the Fitrockr project.

3.4 Wearable and sensor data

Fitrockr may receive data from supported wearable devices, sensors and other connected systems.

Depending on the device and integration, this may include:

• heart rate;

• resting heart rate;

• heart-rate variability;

• activity;

• steps;

• distance;

• calories;

• sleep;

• respiration;

• blood oxygen / SpO2;

• body temperature;

• blood glucose information where provided through supported integrations;

• stress and recovery metrics;

• workouts;

• movement data;

• accelerometer and gyroscope data;

• device status;

• battery information;

• other physiological, biometric or sensor measurements made available by the relevant device or integration.

The precise data collected depends on the device, integration and permissions enabled.

3.5 Health and wellness information

Depending on the use case, Fitrockr may process information concerning:

• physical health;

• physiological measurements;

• medical or health-related information provided by you;

• symptoms;

• health assessments;

• health-related questionnaires;

• lifestyle information;

• medication information where provided;

• blood or laboratory results where manually entered or imported;

• health-related goals;

• health or fitness assessments.

Some of this information may constitute special-category health data under the GDPR or consumer health data or sensitive personal information under applicable U.S. laws.

3.6 Location data

Certain Fitrockr applications may process location information, including precise location information obtained from your mobile device.

Location functionality may be used, depending on the configuration, to:

• record geographic information associated with an activity;

• display routes or activities;

• support location-based functionality;

• support connectivity between a mobile device and a wearable or sensor;

• provide services requested by you or the organization operating the service.

Where technically required for the relevant functionality, location information may be collected while an application operates in the background.

You can control location permissions through your device’s operating-system settings, subject to the functionality of the particular Fitrockr application.

We do not use precise location information for purposes unrelated to the relevant Fitrockr functionality unless separately disclosed and, where required, consented to.

3.7 Surveys, ePROs and assessments

Fitrockr may process information entered into:

• surveys;

• electronic patient-reported outcomes (ePROs);

• electronic clinical outcome assessments (eCOAs);

• ecological momentary assessments (EMAs);

• questionnaires;

• diaries;

• tasks;

• assessments;

• participant-reported measurements.

The contents of these assessments depend on the project.

3.8 Usage, technical and security information

We may process:

• IP address;

• device type;

• operating system;

• application version;

• browser information;

• device identifiers;

• crash information;

• diagnostic information;

• timestamps;

• login and authentication events;

• API requests;

• security logs;

• audit logs;

• information concerning use of the Fitrockr platform.

3.9 Communications

If you contact us, we may process:

• your name;

• email address;

• organization;

• correspondence;

• support requests;

• attachments;

• information necessary to resolve your request.

4. Sources of personal data4. Sources of personal data

We may obtain personal data:

1. directly from you;

2. from your mobile device;

3. from wearable devices and sensors;

4. from health-data platforms and APIs that you or an authorized organization connect to Fitrockr;

5. from healthcare providers, research organizations, employers, insurers, coaches or other Fitrockr customers;

6. from administrators of a Fitrockr project;

7. from integrations and third-party systems;

8. automatically when you use Fitrockr;

9. from other sources where permitted by applicable law.

Where personal data is received from a source other than you, the applicable privacy information will identify the relevant source where required by law.

5. Why do we process personal data?5. Why do we process personal data?

We process personal data only for defined and legitimate purposes.

Depending on the applicable Fitrockr service, these purposes may include:

5.1 Providing Fitrockr services

We process personal data to:

• create and administer accounts;

• authenticate users;

• connect wearable devices;

• collect and synchronize wearable and sensor data;

• store and display data;

• provide dashboards;

• provide analytics and reports;

• provide APIs;

• provide monitoring and alerts;

• provide surveys and assessments;

• support challenges and competitions;

• provide coaching functionality;

• provide other services requested by you or our customer.

5.2 Research and clinical projects

Where Fitrockr is used for research or clinical projects, we may process personal data on behalf of the relevant research organization or sponsor in accordance with the applicable project documentation, instructions and agreements.

Fitrockr does not independently determine the scientific purpose of a research project merely because the Fitrockr platform is used to conduct it.

5.3 Healthcare and patient monitoring

Where Fitrockr is used in healthcare, we process data to provide the functionality requested by the relevant healthcare organization or other customer.

Fitrockr does not provide medical diagnosis or treatment merely by providing software functionality.

Any medical or healthcare decisions remain the responsibility of the relevant healthcare professional or organization unless expressly stated otherwise.

5.4 Security and fraud prevention

We process technical and account information to:

• protect Fitrockr;

• detect and prevent unauthorized access;

• detect abuse;

• investigate security incidents;

• maintain system integrity;

• protect users and customers;

• maintain audit trails;

• comply with security requirements.

5.5 Customer support

We process information necessary to respond to inquiries, diagnose problems and provide technical support.

5.6 Legal and regulatory compliance

We may process personal data where necessary to:

• comply with legal obligations;

• respond to lawful requests;

• establish, exercise or defend legal claims;

• maintain legally required records;

• comply with regulatory requirements.

5.7 Communications

We may use contact information to send:

• transactional communications;

• service notifications;

• security notifications;

• technical information;

• account-related communications.

Where legally required, marketing communications are sent only after obtaining the necessary consent or on another legally permitted basis.

You may unsubscribe from marketing communications at any time.

5.8 Product improvement

Where legally permitted and subject to applicable contractual and project restrictions, we may use appropriately limited technical and usage information to:

• maintain;

• troubleshoot;

• test;

• secure;

• improve

Fitrockr products and services.

We do not use identifiable health information from customer projects for unrelated product-development purposes unless an appropriate legal basis, authorization, consent or contractual arrangement exists.

6. Legal bases under EU/EEA data protection law

Where the GDPR applies, we process personal data only where a lawful basis exists.
Depending on the processing, the legal basis may include:
Performance of a contract — Article 6(1)(b) GDPR
For example:
• account administration;
• provision of requested Fitrockr services;
• synchronization of connected devices;
• customer support;
• billing and service administration.
Legal obligation — Article 6(1)(c) GDPR
Where processing is necessary to comply with a legal obligation.
Legitimate interests — Article 6(1)(f) GDPR
Where appropriate, we may process personal data for legitimate interests such as:
• information security;
• prevention of fraud and abuse;
• operation and maintenance of IT systems;
• service quality;
• protection of legal rights;
• limited service communications.
Where we rely on legitimate interests, we consider the interests, fundamental rights and freedoms of the affected individuals.
Consent — Article 6(1)(a) GDPR
Where required, we process personal data on the basis of consent.
Consent is voluntary and may be withdrawn at any time.
Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Special-category data — Article 9 GDPR
Where we process health data, biometric data or other special-category data under Article 9 GDPR, we rely on an applicable exception under Article 9 in addition to an Article 6 legal basis.
Depending on the use case, this may include:
• explicit consent under Article 9(2)(a);
• processing necessary for healthcare or related purposes under Article 9(2)(h);
• processing for scientific research purposes under Article 9(2)(j);
• another applicable exception under Article 9 or applicable national law.
The applicable Article 6 and Article 9 legal bases may differ between projects.
 

7. Controller and processor relationships

Fitrockr is designed to support both direct-to-user services and services provided on behalf of organizations.
Where a customer determines:
• why personal data is processed;
• which data is collected;
• which individuals participate;
• how the data is used; and
• the relevant retention requirements,
the customer may be the controller, while Digital Rebels GmbH acts as the processor.
In such cases:
• we process personal data only in accordance with the customer’s documented instructions, subject to applicable law;
• the customer is responsible for determining the lawful basis for the processing;
• the customer is responsible for providing appropriate participant or employee privacy information;
• the parties may enter into a Data Processing Agreement under Article 28 GDPR;
• Fitrockr may use approved subprocessors where authorized by the applicable agreement.
Where Digital Rebels GmbH determines the purposes and means of processing, Digital Rebels GmbH acts as controller.
 

8. Who can access personal data?

Access to personal data is restricted according to the applicable role, project configuration and need for access.
Depending on the service, information may be accessible to:
• you;
• authorized administrators;
• the organization operating the relevant Fitrockr project;
• authorized healthcare professionals;
• authorized researchers;
• authorized coaches;
• authorized customer personnel;
• Fitrockr personnel who require access for support, security or service administration;
• authorized subprocessors and service providers.
Fitrockr uses role-based access controls and other security measures to restrict access.
For research, healthcare and other customer-controlled projects, the customer determines which authorized users can access participant data, subject to the customer’s configuration and contractual arrangements.
 

9. Fitness challenges and community features

Where Fitrockr provides community, competition or fitness-challenge functionality, certain information may be visible to other participants according to the relevant configuration.
Depending on the configuration, this may include:
• name or display name;
• profile photograph;
• country;
• fitness tracker;
• points;
• steps;
• activity minutes;
• distance;
• rankings;
• leaderboard position;
• activity information;
• synchronization information.
Information intended to be private is not made publicly available through these features.
You should not enter information into a public or community-facing profile that you do not want other participants to see.
 

10. Sharing personal data with third parties

We do not sell personal data in exchange for monetary consideration.
We may disclose personal data to third parties where necessary and legally permitted, including:
Customers and project organizations
Where Fitrockr operates on behalf of a customer, the customer may receive or access personal data according to the applicable project configuration and agreement.
Service providers and subprocessors
We may use third-party service providers for services such as:
• cloud hosting;
• infrastructure;
• databases;
• email delivery;
• monitoring;
• security;
• customer support;
• analytics;
• communications;
• payment processing;
• software infrastructure.
Wearable and platform providers
Where you connect a wearable or health-data service, data may be exchanged with the relevant provider according to the permissions and integration you authorize.
Those providers may process your data under their own privacy policies.
Legal requirements
We may disclose information where required by law or where necessary to:
• comply with legal process;
• respond to lawful governmental requests;
• protect the rights or safety of Fitrockr, our customers or users;
• investigate fraud, abuse or security incidents;
• establish or defend legal claims.
 

11. International data transfers

Digital Rebels GmbH is established in Germany.
Depending on the selected hosting environment, customer configuration, service provider and project, personal data may be processed in:
• the European Economic Area;
• the United States;
• other countries in which an authorized service provider operates.
Where the GDPR applies and personal data is transferred outside the EEA, we use an appropriate transfer mechanism under Chapter V GDPR.
Depending on the circumstances, this may include:
• an adequacy decision of the European Commission;
• the EU-U.S. Data Privacy Framework, where the recipient is eligible and certified;
• Standard Contractual Clauses;
• other legally recognized transfer mechanisms.
Where required, we assess the relevant transfer circumstances and implement appropriate supplementary safeguards.
 

12. Data security

We use appropriate technical and organizational measures designed to protect personal data against:
• unauthorized access;
• unauthorized disclosure;
• accidental loss;
• destruction;
• alteration;
• misuse;
• other unlawful processing.
Depending on the service and risk, these measures may include:
• encryption in transit;
• encryption at rest where appropriate;
• access controls;
• role-based permissions;
• authentication controls;
• logging and monitoring;
• vulnerability management;
• backups;
• segregation of environments;
• secure software-development practices;
• incident-management procedures;
• employee confidentiality obligations;
• security testing.
No internet-based service can guarantee absolute security.
If a security incident occurs, we will respond in accordance with applicable law and contractual obligations.
 

13. Data retention

We retain personal data only for as long as necessary for the purposes for which it is processed, unless a longer retention period is required or permitted by law.
The appropriate retention period depends on:
• the type of data;
• the purpose of processing;
• the contractual relationship;
• the relevant research or clinical project;
• legal and regulatory requirements;
• limitation periods;
• security and audit requirements.
For customer-controlled projects, retention may be determined by the customer and the applicable project or contractual requirements.
Examples of different retention categories may include:
• account information;
• participant data;
• health data;
• research data;
• consent records;
• billing information;
• support communications;
• security logs;
• audit records;
• backups.
When personal data is no longer required, it is deleted, anonymized or otherwise securely disposed of in accordance with applicable requirements.
Deletion from active systems may not immediately remove information from encrypted backups or legally required archives. Such information is deleted or rendered inaccessible in accordance with our backup and retention procedures.
 

14. Your rights under the GDPR

Where the GDPR applies, you may have the following rights:
Right of access
You may request confirmation as to whether we process your personal data and request access to that data.
Right to rectification
You may request correction of inaccurate or incomplete personal data.
Right to erasure
In certain circumstances, you may request deletion of your personal data.
Right to restriction
In certain circumstances, you may request that processing of your personal data be restricted.
Right to data portability
Where applicable, you may request personal data you have provided to us in a structured, commonly used and machine-readable format or request its transmission to another controller.
Right to object
You may object to certain processing, including processing based on legitimate interests and certain processing for direct marketing.
Right to withdraw consent
Where processing is based on consent, you may withdraw that consent at any time.
Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Rights concerning automated decision-making
Where applicable, you have rights relating to decisions based solely on automated processing, including profiling, where those decisions produce legal or similarly significant effects.
Where Fitrockr performs automated analysis or profiling, the applicable privacy information will explain the relevant processing and your rights.
 

15. Exercising your rights

You can contact us at:
support@fitrockr.com
or:
Digital Rebels GmbH
Friedrichstr. 155
10117 Berlin
Germany
We may need to verify your identity before responding to a request.
If Fitrockr processes your data on behalf of another organization, we may forward your request to that organization or direct you to the relevant controller where appropriate.
We generally respond to GDPR requests within the periods required by applicable law.
 

16. Right to complain to a supervisory authority

If you believe that your personal data is being processed unlawfully, you have the right to lodge a complaint with a competent data protection supervisory authority.
For Digital Rebels GmbH’s establishment in Berlin, the relevant supervisory authority may be:
Berliner Beauftragte für Datenschutz und Informationsfreiheit
Alt-Moabit 59–61
10555 Berlin
Germany
Email: mailbox@datenschutz-berlin.de
You may also contact the data protection authority in your place of residence, place of work or the place of the alleged infringement, where permitted under applicable law.
 

17. Automated processing, profiling and health AI

Fitrockr may provide functionality involving:
• statistical analysis;
• health and fitness assessments;
• risk prediction models;
• machine-learning models;
• automated data analysis;
• personalized recommendations;
• automated alerts.
The availability and purpose of these functions depend on the specific Fitrockr product and project.
Fitrockr does not use automated processing to make decisions producing legal or similarly significant effects concerning an individual unless such processing is lawfully permitted and appropriate safeguards are implemented.
Where applicable, individuals will receive information about:
• the existence of automated processing;
• the relevant purposes;
• the general logic involved;
• the significance and envisaged consequences;
• applicable rights.
Where legally required, appropriate safeguards may include the right to obtain human intervention, express a point of view and contest a decision.
 

18. Artificial intelligence and model training

Fitrockr may use artificial intelligence, machine learning or statistical models to provide specific product functionality.
Unless expressly disclosed and legally permitted, we do not use identifiable health data belonging to customers or research participants to train general-purpose AI models for unrelated purposes.
Where customer data is used for:
• model development;
• validation;
• scientific research;
• statistical analysis;
• product improvement;
the applicable purpose, legal basis, contractual authorization and data protection requirements must be satisfied.
Where possible, data used for such purposes will be aggregated, anonymized or appropriately pseudonymized.
 

19. Research and clinical trials

Where Fitrockr is used in research or clinical trials, the relevant research organization or sponsor generally determines:
• the purpose of the study;
• the categories of participants;
• the data collected;
• the legal basis;
• applicable consent requirements;
• retention periods;
• research disclosures.
Fitrockr may act as a processor for the relevant organization.
Participants should therefore also review the study-specific privacy notice and informed-consent documentation.
Deletion or correction rights may be subject to limitations under applicable research, clinical-trial or other laws.
 

20. Healthcare services

Fitrockr provides software and data-management functionality.
Unless expressly stated otherwise, Fitrockr is not itself providing medical diagnosis or treatment.
Health information processed through Fitrockr may be subject to additional laws depending on the customer, jurisdiction and purpose.
Where Fitrockr processes protected health information on behalf of a HIPAA covered entity, Fitrockr may act as a Business Associate and the applicable Business Associate Agreement governs the relevant processing.
HIPAA applicability depends on the specific relationship and processing arrangement; the fact that Fitrockr processes health information does not by itself make every Fitrockr service subject to HIPAA.
 

21. United States privacy

Where U.S. privacy laws apply, Fitrockr processes personal information in accordance with applicable federal and state requirements.
Depending on the applicable jurisdiction and Fitrockr’s role, these laws may include:
• the Federal Trade Commission Act;
• the FTC Health Breach Notification Rule;
• HIPAA and its implementing regulations;
• California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act;
• Washington My Health My Data Act;
• Colorado Privacy Act;
• Connecticut Data Privacy Act;
• Virginia Consumer Data Protection Act;
• Oregon Consumer Privacy Act;
• Texas Data Privacy and Security Act;
• other applicable state privacy or health-data laws.
Not every law applies to every Fitrockr service or individual.
The applicable rights and obligations depend on:
• the individual’s location;
• the Fitrockr service;
• the nature of the customer relationship;
• the categories of information;
• Fitrockr’s role as controller, processor, service provider or business associate;
• applicable statutory thresholds and exemptions.
 

22. California Privacy Notice

If the California Consumer Privacy Act applies to the processing, California residents may have additional rights, including rights relating to:
• access to personal information;
• deletion;
• correction;
• information about categories of personal information collected;
• information about purposes and disclosures;
• sensitive personal information;
• opting out of certain sales or sharing;
• certain profiling or automated decision-making activities;
• non-discrimination for exercising applicable rights.
Categories of information
Depending on the service, Fitrockr may collect categories of personal information corresponding to categories under California law, including:
• identifiers;
• customer records information;
• commercial or transaction information;
• internet or electronic network activity;
• geolocation information;
• professional or employment-related information;
• inferences;
• health and other sensitive personal information.
Sale and sharing
Fitrockr does not sell personal information for monetary consideration.
Sensitive personal information
Certain Fitrockr data may constitute sensitive personal information under California law, including health information, precise geolocation and certain biometric information.
Such information is used only for disclosed and permitted purposes.
California residents may exercise applicable rights by contacting:
support@fitrockr.com
We will verify requests as required by law.
 

23. Washington Consumer Health Data

Where the Washington My Health My Data Act applies, Fitrockr may process consumer health data including, depending on the service:
• health conditions;
• symptoms;
• vital signs;
• physiological measurements;
• biometric information;
• reproductive or sexual health information where provided;
• health-related assessments;
• precise location information in circumstances covered by the law;
• inferences concerning health.
The categories of consumer health data collected, purposes, sources, categories of data shared and categories of recipients are described throughout this Privacy Policy.
Consumer health data is not sold unless permitted under applicable law and any required valid authorization has been obtained.
Where required, consumer health data is collected and shared only with the consent or other lawful authorization required by Washington law.
Washington consumers may have rights to:
• confirm whether consumer health data is being processed;
• access consumer health data;
• delete consumer health data;
• withdraw applicable consent;
• appeal certain refusals.
Requests may be submitted to:
support@fitrockr.com
Fitrockr does not use geofencing technology around healthcare facilities for purposes prohibited by applicable Washington law.
 

24. HIPAA

Where Fitrockr acts as a Business Associate under HIPAA, applicable HIPAA requirements are addressed through the relevant contractual arrangements, including a Business Associate Agreement where required.
Depending on the applicable arrangement, Fitrockr may be required to:
• safeguard protected health information;
• use and disclose PHI only as permitted;
• implement appropriate administrative, physical and technical safeguards;
• report certain security incidents;
• assist the covered entity with applicable obligations;
• return or destroy PHI at the end of the applicable relationship, subject to applicable exceptions.
If Fitrockr is not acting as a HIPAA covered entity or business associate for a particular service, HIPAA may not apply to that service.
Other federal or state privacy laws may nevertheless apply.
 

25. U.S. health-data breach requirements

Depending on the service and Fitrockr’s role, a security incident involving health information may trigger notification obligations under:
• HIPAA Breach Notification Rule;
• FTC Health Breach Notification Rule;
• applicable state breach-notification laws;
• contractual requirements.
We maintain incident-response procedures designed to identify, investigate and respond to security incidents and to make legally required notifications.
 

26. Cookies and similar technologies

Fitrockr websites may use cookies and similar technologies.
These technologies may be used for:
• essential website functionality;
• authentication;
• security;
• remembering preferences;
• analytics;
• marketing, where applicable and lawfully permitted.
Where consent is required, non-essential cookies are activated only after the relevant consent has been obtained.
You can manage cookie preferences through the applicable cookie-consent interface or your browser settings.
 

27. Third-party websites and services

Fitrockr may contain links to third-party websites or integrate third-party services.
Third parties operate under their own privacy policies.
We are not responsible for the privacy practices of third parties except to the extent required by applicable law or our contractual obligations.
Where you connect a third-party wearable or health-data service, that provider may independently process your information.
 

28. Children’s privacy

Fitrockr services are not generally directed at children unless a particular project has been specifically designed and legally approved for participation by children or minors.
Where children or minors participate in a project, the applicable customer, controller and project documentation are responsible for implementing legally required consent, authorization and safeguarding measures.
Where Fitrockr itself determines that it has collected personal data from a child in circumstances where such collection was not permitted, we will take appropriate steps to address the situation.
 

29. Data relating to employees and workplace programs

Where Fitrockr is used for corporate wellness, workplace safety or employee-related programs, the employer or other customer may determine the purposes and means of processing.
Fitrockr does not independently determine employment-related decisions based on employee health data unless expressly agreed and legally permitted.
Where applicable, customer configurations should be designed to minimize access by employers to individual health information and to provide aggregated or appropriately restricted information where individual-level information is not necessary.
The customer’s employee privacy notice and applicable employment/privacy laws also apply.
 

30. Data relating to defense and sensitive projects

Fitrockr may be deployed in defense, government, military or other high-security environments.
Such deployments may use:
• dedicated hosting;
• local hosting;
• private infrastructure;
• isolated infrastructure;
• air-gapped environments.
The applicable contractual security and privacy requirements may differ from those applicable to standard Fitrockr cloud services.
Project-specific contractual documentation takes precedence where it imposes additional privacy or security requirements.
 

31. Data anonymization and pseudonymization

Fitrockr may support:
• identifiable data;
• pseudonymized data;
• anonymized data.
Pseudonymized information remains personal data where an individual can still be identified using additional information.
Information that has been irreversibly anonymized and can no longer reasonably be linked to an individual is no longer personal data under applicable data-protection law.
Fitrockr applies appropriate technical and organizational safeguards when pseudonymization or anonymization is used.
 

32. Data portability and exports

Depending on the service and project configuration, Fitrockr may allow authorized users or customers to export data in formats such as:
• CSV;
• XLS/XLSX;
• JSON;
• PDF;
• API-based formats.
Availability of exports depends on the user’s role and the applicable customer configuration.
 

33. Data requests when Fitrockr is a processor

If Fitrockr processes your personal data solely on behalf of a customer, you may need to direct your request to that customer.
For example, if a hospital operates a clinical study using Fitrockr, the hospital may be the controller and responsible for responding to requests concerning the study.
Fitrockr will provide reasonable assistance to customers in responding to legally valid data-subject requests as required by the applicable agreement and law.
 

34. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect:
• changes to Fitrockr services;
• changes to applicable law;
• changes to data-processing activities;
• changes to security practices;
• changes to third-party services.
The updated version will be published on this page with a revised “Last updated” date.
Where required by law, we will provide additional notice or obtain consent before material changes take effect.
 

35. Contact

If you have questions about this Privacy Policy or Fitrockr’s processing of personal data, contact:
Digital Rebels GmbH
Friedrichstr. 155
10117 Berlin
Germany
Email:
support@fitrockr.com
 

36. Summary of important privacy principles

Fitrockr follows these principles when processing personal data:
• We process personal data for defined purposes.
• We process health and other sensitive information with the additional safeguards required by applicable law.
• We restrict access to authorized persons.
• We do not sell personal data for monetary consideration.
• We use contractual safeguards when processing data for customers.
• We use appropriate security measures.
• We retain personal data only as long as necessary or legally required.
• We provide applicable privacy rights.
• We provide additional safeguards for international transfers.
• We provide additional protections where U.S. health-data or state privacy laws apply.
• We distinguish between Fitrockr acting as a controller and Fitrockr acting as a processor.

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Fitrockr is a leading health and fitness data analytics platform that empowers organizations to connect, manage and analyze data from wearables. Designed for research, clinical studies, healthcare, coaching and fitness gamification, Fitrockr enables seamless integration of biometric and activity data, providing deep insights through advanced analytics, dashboards, reports and raw data downloads. Automated alerting, push notifications, surveys and outcome assessments support data collection. With a focus on data privacy, security, and local hosting options, Fitrockr supports global institutions in transforming raw health data into actionable outcomes. Learn more at www.fitrockr.com.