Penhold Deutsche Version

Privacy Policy

This policy covers the Penhold app (sections 2–7) and this website with its waitlist (sections 8–15).

1. Controller

Benedict Meeske
Prenzlauer Allee 127, 10409 Berlin, Germany
Email: ttbene99@gmail.com

The app

2. Data in the app

Without your consent, the app does not collect any personal data about you as a person; for the purely technical update check, see section 3; for checking purchases, section 4. Everything you create in the app (generated training sessions, your training plan, your favourites and your ticked-off exercises) is stored solely on your device. There is no user account and no sign-in. Deleting the app deletes this data. Without your consent to usage analytics, we never have access to it; it is then transmitted neither to us nor to any third party. If you agree, we learn certain details from it. Section 5 sets out which.

The app shows no ads and sets no cookies. Usage analytics and ad measurement only run if you agree to them (sections 5 and 6). After a new installation, the app asks you on first launch; you can change your choice at any time in Settings under ‘Privacy’.

3. App program updates

On launch, the app checks whether a newer program version is available. This request goes to Expo (Expo, Inc., USA), our service provider for delivering app updates.

Only technical information is transmitted: app and runtime version, platform, and a randomly generated installation identifier that identifies neither your name nor your device. As with any request on the internet, your IP address is technically transmitted in the process. No content from the app is transmitted.

The legal basis is our legitimate interest in keeping the app up to date and free of errors (Art. 6(1)(f) GDPR). The data is transferred to servers in the USA; Expo is certified under the EU-US Data Privacy Framework, for which the European Commission has issued an adequacy decision (Art. 45 GDPR). We do not store this data ourselves; Expo retains it only as long as necessary to deliver updates.

4. Purchases and subscriptions

If you subscribe, buy Lifetime or start a free trial, payment is handled exclusively by Apple or Google. We do not receive your payment details.

To determine whether your purchase is valid, we use RevenueCat (RevenueCat, Inc., USA) as a processor. The data transmitted is a randomly generated identifier that contains neither your name nor your email address, your Penhold purchases (product, dates, term, store), country and currency, and, as with any request on the internet, your IP address.

The legal basis is the performance of the purchase contract (Art. 6(1)(b) GDPR). The transfer to the USA is based on the European Commission’s standard contractual clauses (Art. 46(2)(c) GDPR). So that the app also works without an internet connection, it stores locally on your device when your purchase was last confirmed.

5. Usage analytics (only with your consent)

If you agree to usage analytics, we record how the app is used. This shows us where the app needs to become clearer. We use PostHog (PostHog Inc., USA) as a processor for this; the data is stored on servers in the EU (Frankfurt).

The following is recorded: which steps of the introduction you view, complete or skip, and which tips the app shows you; your answers in the introduction quiz (chosen training goals, playing level, your playing hand and your partner’s, number of training days per week, chosen number of exercises) and the size of the plan created from them; whether you switch on reminders; whether the purchase screen appears, which pricing option you select and whether a purchase is started, completed, cancelled or restored; whether you have cancelled your free trial, whether an offer to keep going is shown to you and how you respond to it; and two milestones (your first ticked-off training day and your first weekly goal reached), each with the number of days since the app was set up.

These events are transmitted together with a randomly generated identifier, technical information (app version, operating system, device type, language) and, as with any request on the internet, your IP address. The data is pseudonymous: the identifier only groups the events of your installation; there is no name or account attached to it. PostHog does not store the IP address and does not evaluate your location. We do not combine this data with the purchase data held by RevenueCat, a name or an email address.

The legal basis is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). You can withdraw it at any time in Settings under ‘Privacy’; the app then records nothing new and deletes the identifier on your device. The recorded events are deleted after twelve months at the latest.

6. Ad measurement (only with your consent)

If you agree to ad measurement, we measure whether our ads on Instagram and Facebook bring new users to Penhold. For this, Meta’s software development kit is built into the app. It reports to Meta that the app was installed and opened, together with an anonymous identifier generated by Meta, your device’s advertising ID, technical information (device type, operating system, app version) and your IP address. If you start a free trial, subscribe or buy Lifetime, RevenueCat (section 4) additionally reports this to Meta with the anonymous identifier, the product and the price. Payment details, names or training content are not sent to Meta.

On iPhone, this only happens if you also allow tracking in Apple’s prompt. If you decline there, ad measurement stays off.

We and Meta Platforms Ireland Ltd. (Merrion Road, Dublin 4, Ireland) are joint controllers for collecting this data and transmitting it to Meta (Art. 26 GDPR); this is governed by Meta’s Business Tools Terms (facebook.com/legal/terms/businesstools). You can exercise your rights with us or with Meta. Meta alone is responsible for any further processing, for example to deliver and improve ads; Meta’s Privacy Policy applies (facebook.com/privacy/policy). Meta may transfer data to Meta Platforms, Inc. in the USA, which is certified under the EU-US Data Privacy Framework (Art. 45 GDPR).

The legal basis is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). You can withdraw it at any time in Settings under ‘Privacy’; from then on the app sends nothing more to Meta, and the anonymous identifier is deleted at RevenueCat.

7. Crash reports

The app itself contains no crash-reporting software. If you have allowed your device to share diagnostic data (iOS: ‘Share With App Developers’, Android: ‘Usage & diagnostics’ with Google), Apple or Google provides us with automatically generated crash reports containing technical information such as device model, operating system version and the point in the program at which the app crashed (Art. 6(1)(f) GDPR). If you take part in a test version via Apple TestFlight or a Google Play test, we additionally receive the feedback you actively submit there.

Apple and Google are each an independent controller for collecting these reports; their respective privacy policies apply. Whether you allow this sharing is entirely up to you, in your device settings.

This website

8. What data we collect

When you join the waitlist, we process your email address and the time of your consent (the checkbox in the signup form). Because sign-up uses the double opt-in procedure, our sending provider Brevo additionally stores the IP address and the time of your sign-up and of your confirmation as proof of your consent (Art. 6(1)(f) GDPR: legitimate interest in being able to prove consent, Art. 7(1) GDPR). We do not collect any further data (no name, club, etc.).

9. Purpose and legal basis

The sole purpose is to notify you about the app launch and to send you occasional project updates. The legal basis is your consent pursuant to Art. 6(1)(a) GDPR. You can withdraw it at any time via the unsubscribe link in every email.

10. Recipients / processors

We use Brevo (Sendinblue GmbH / Sendinblue SAS, EU) to send emails. A data processing agreement pursuant to Art. 28 GDPR is in place with the provider. Your email address is stored there for list management and sending. We do not use open or click tracking within the emails.

11. Storage period

We store your email address until you unsubscribe or the project is discontinued. After withdrawal it is deleted promptly. We additionally keep the proof of your consent and a suppression entry (Brevo keeps unsubscribed addresses on a blocklist so they are not emailed again) until the statutory limitation period expires (generally 3 years, § 195 BGB).

General

12. Your rights

13. Hosting of this website

The site is hosted on Vercel (Vercel Inc., USA). Technically necessary server logs (e.g. IP address, timestamp and the page requested) may be generated; no cookie-based analytics are used.

The legal basis is our legitimate interest in a functioning and secure website (Art. 6(1)(f) GDPR). Processing also takes place on servers in the USA; Vercel Inc. is certified under the EU-US Data Privacy Framework, for which the European Commission has issued an adequacy decision (Art. 45 GDPR). These server logs are only available to us briefly; we do not store them separately ourselves.

14. Audience measurement

To see how often these pages are opened, we use Vercel Web Analytics, the counting feature of our host (Vercel Inc., USA). It records the time and the page requested, the referring page, an approximate location (country, region, city) as well as operating system, browser and device type.

The service sets no cookies and stores nothing on your device. In order to tell repeat visits from new ones, Vercel derives an identifier from your request on the server side; your IP address is not stored in the process, and the identifier is discarded after 24 hours. Recognising you across sites, or building a profile about you as a person, is therefore not possible.

The legal basis is our legitimate interest in designing this website to meet actual demand (Art. 6(1)(f) GDPR). For processing in the USA, what is said in section 13 applies. You may object to this processing at any time (Art. 21 GDPR).

15. Fonts and scripts

All fonts, images and JavaScript libraries on this site are served from the same server as the site itself, including the counting script named in section 14. Nothing is loaded from third-party networks, in particular not from Google Fonts, cdnjs or jsDelivr. Your IP address is therefore not passed on to any additional provider. The site sets no cookies and consequently needs no consent banner.

Last updated: 7 October 2026.

This is a courtesy translation. The German version is the legally binding one.