Privacy Policy – Iron Pulse

Effective Date: [09/11/2025]

This Privacy Policy (“Policy”) describes how Iron Pulse, Inc. (“Iron Pulse,” “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes your personal information when you use our Services, including our website and mobile application. It also explains your choices and rights regarding your personal information. This Policy is part of our Terms of Service, and any terms not defined herein have the meanings set forth in the Terms of Service.

Age Requirement

You must be at least 18 years old to use Iron Pulse. Do not use our Services if you are under the age of 18. Our Services are not designed or intended for children or individuals under 18 years of age.

We have implemented technical measures to prevent account creation or use of our Services by anyone under 18. If we become aware that a person under 18 has provided personal information to us, we will investigate and, if necessary, take steps to delete that data and remove the associated account.

Quick Links to Key Privacy Information

For your convenience, we’ve included quick links to help you easily navigate our Privacy Policy and understand how we handle your data:

• What information does Iron Pulse collect?
  We collect information directly from you when you create an account, interact with our Services, and through third parties. Learn more
• How does Iron Pulse use my information?
  We use your information to deliver our Services, show you relevant content, and improve the quality of our offerings. Learn more
• Does Iron Pulse sell my personal information?
  No. Iron Pulse does not sell your personal information. Learn more
• How does Iron Pulse share my information?
  We share information with service providers that help operate our app and process payments, when required by law or legal process, or to protect the rights, property, and safety of our company, our users, or others. Learn more

Personal Information We Collect

We may collect personal information directly from you, automatically through your use of the Services, and from third parties.

Personal Information Collected Directly from You

• Account and Profile Information. This includes your name, Apple ID, general location information (country/ZIP code), profile image or photo (if you choose to provide one), username, date of birth, and gender.
• Activity Diary Data. Some features of our Services allow you to voluntarily share information about your physical activities and workouts. This may include the following data:
  • Active Energy
  • Resting Energy
  • Steps
  • Weight
  • Height
  • Workout details
  • VO₂ Max
  • Cardio Fitness
  • Date of Birth
  • Gender
  • Protein, Carbohydrate, and Fat intake

  Activity Diary Data may include sensitive personal information if it indicates or allows someone to infer details about your health condition.

• Communications with Iron Pulse.
  This includes your Apple ID email address, name, and any other content you provide when interacting with us, such as messages exchanged with our Support Center team.
• Information Shared with Other Iron Pulse Users.
  We may collect personal information you choose to share with other Iron Pulse users (such as your name, user ID, and physical activity data) through your participation in Challenges.
• Challenges.
  This may include information related to your participation in challenges created by other users or by yourself. When you create or join a challenge, we may collect your name, profile image (if applicable), and physical activity data recorded during the challenge.
• Workouts.
  This may include information related to your initiated training sessions and their synchronization with the corresponding list of workouts on your Apple Watch. If no watch is connected, the system will calculate average values based on the data available in HealthKit (regarding heart rate) and on predefined MET (Metabolic Equivalent of Task) values, determined according to your age, gender, and the selected type of workout.
• Settings and Other Requests.
  This may include your preferences, such as daily goal settings (calories, exercise, and steps) and nutrient goals (proteins, carbohydrates, and fats), settings related to Apple HealthKit data display, Apple Watch synchronization, and any other preferences or requests you share when interacting with us.
• Payment Information.
  If you purchase a basic or premium subscription through our app, we store a record of the payment transaction processed via a third-party payment platform (Apple Pay). Iron Pulse uses this platform solely to facilitate transactions and retains transaction records through a secure third-party service.

Personal Information Collected Automatically

Iron Pulse may collect usage and device data. This may include your operating system or device information (such as IP address, OS version, and other technical details), internet service provider, mobile carrier, general location (including inferred location based on IP address), actions you take while using the Services, frequency and duration of activity, links you click, and other interaction details.

This data is necessary for the proper functioning of the application, system stability, and performance across supported devices.

Personal Information Received from Third Parties

• We may receive information about you from other sources, such as connected third-party devices (Apple Watch, fitness bands, etc.).
• Information Shared with Other Iron Pulse Users.
  We may collect personal information you choose to share with other Iron Pulse users (such as your name, user ID, and physical activity data) through your participation in Challenges.
• Information Collected from Connected Health Devices.
  Certain connected devices, such as heart rate monitors, continuous glucose monitoring devices, activity trackers, exercise equipment, scales, and/or wearables that integrate with the Services, may allow us to collect Activity Diary Data with your permission.
• Apple HealthKit Data.
  With your permission, we may also collect relevant data from your device’s health and fitness repository, such as Apple’s HealthKit. Any data you provide to HealthKit is governed by Apple’s Terms and Conditions and Privacy Policy. The unique information you choose to share from HealthKit is not used by Iron Pulse for marketing or advertising purposes, nor is it transferred to third parties for such purposes.

Aggregated, Deidentified, or Anonymized Information

Please note that we may aggregate, de-identify, or anonymize information so that it will no longer be considered personal information under applicable law. We may use and disclose de-identified information for purposes consistent with those described in this Policy or as otherwise permitted by applicable law.

How We Use Personal Information

• Provide Our Services.
  We use your personal information in connection with the provision, administration, and management of the Services, including managing your account, providing troubleshooting and technical support, and operating our day-to-day business activities.
• Communicate with You.
  We use your personal information to communicate with you, including responding to your questions and requests. We may also use it to send you communications requesting information, seeking feedback, or providing administrative updates, such as changes to our terms, conditions, and policies.
• Respond to Your Requests to Exercise Your Rights.
  We use your personal information to respond to your requests to exercise your rights regarding your personal information.
• Cross-Device Tracking.
  We and our third-party partners may use the information we collect to help identify other devices you use (e.g., an Apple Watch). This means that your online activity and device location may be combined with information collected from your other browsers or devices. If our systems determine that a device is associated with you, we may use this information to deliver push notifications, limit the number of challenges you can create across devices, and track the effectiveness of your physical activities across devices.
• Analyze Ad Performance.
  We work with third-party analytics providers to analyze traffic, evaluate usage of the Services (including our website), and measure the performance of our advertisements. These providers may use tracking technologies to collect information for these purposes.
• Plan and Manage Workouts.
  We use your personal information to assist with workout planning activities, including creating workout categories and preparing workout videos.
• Maintain Security and Protect Rights.
  We use your personal information to help monitor and maintain the security of the Services and our operations. This includes preventing and detecting fraud, unauthorized activities, and other misuse of the Services, as well as protecting you, our business, and others from unlawful or unsafe activity.
• Satisfy Legal Obligations.
  We use your personal information to comply with applicable legal and regulatory requirements and to respond to valid requests and communications from law enforcement authorities, as required by law.
• Manage Pre-Litigation or Litigation Matters.
  We use your personal information to protect and defend our rights and interests in the event of pre-litigation or litigation.
• Carry Out Internal Operations.
  We use your personal information to conduct financial, tax, and accounting audits, and to assess our operations, including privacy, security, and financial controls. We also use it to administer our business, maintain compliance, manage records, and enforce our policies and procedures.
• Carry Out Sales and Business Transactions.
  We may use your personal information in connection with evaluating, negotiating, and/or completing a business transaction (e.g., a merger, divestiture, restructuring, acquisition, reorganization, dissolution, or sale or transfer of assets). This includes situations in which personal information is part of the transferred assets or is otherwise relevant to the transaction.

How We Disclose Personal Information

We disclose personal information to the categories of recipients described below:

• Our Business Partners.
  We may collaborate with other companies to offer our Services and may disclose your personal information to these business partners where necessary or appropriate for the purposes described in this Policy.
• Our Service Providers.
  We may disclose your personal information to third parties that provide business, professional, or technical support services to us and/or perform functions on our behalf to deliver the Services. Such services may include IT and website hosting, payment processing, market research, customer support, data storage, data analytics, auditing, as well as consulting and legal services.
• Other Iron Pulse Users.
  We may disclose your personal information to other Iron Pulse users in connection with certain social features of the Services. For example, we may display personal information (such as your name, profile image, and physical activity data) recorded by the system during your participation in public and private challenges.
• Our Analytics Providers.
  We may disclose your personal information, including device and browser data, as well as activity and usage information, to parties that assist us in performing analytics and measuring the effectiveness of our Services and our online and offline marketing and advertising efforts.
• Relevant Third Parties in Connection with Business Transactions or Reorganizations.
  If we or our affiliates are, or may be, acquired by, merged with, or receive investment from another company, or if any of our assets are, or may be, transferred to another company – whether as part of a bankruptcy or insolvency proceeding or otherwise – we may disclose or transfer your personal information to that company as permitted by applicable law. We may also disclose certain personal information, if necessary, prior to the completion of such a transaction or other corporate event (such as financing or restructuring), to creditors, auditors, and external advisors, including attorneys and consultants.
• Law Enforcement and Regulatory Authorities.
  We may disclose your personal information to comply with applicable legal and regulatory obligations and to respond to legally valid requests and communications from law enforcement authorities, as required by law.
• Other Parties.
  We may disclose your personal information to other parties at your direction or with your consent, or as otherwise permitted by applicable law. For example, if you participate in a challenge, we may disclose your personal information to anyone with access to that challenge and its leaderboard. Finally, we may disclose your personal information to other parties where necessary or appropriate to:
  • comply with applicable law;
  • protect the Services, our rights, and property, or the rights, property, privacy, or safety of others;
  • prevent, detect, investigate, and respond to fraud, unauthorized activities or access, illegal activity, or misuse of the Services;
  • enforce, detect, investigate, and take action in response to violations of the Iron Pulse Terms of Service;
  • allow us to pursue available remedies or limit the damages we may sustain.

Managing Your Personalized Preferences

You have the ability to manage your Iron Pulse account and your preferences as described below.

Push Notifications

We may send you periodic push notifications, including:

• Daily reminders for workout sessions, which occur at 8:00 AM each day.
• Notifications when your friends successfully join your private challenges, sent each time a friend joins a challenge.

You can adjust these settings and disable or enable them in your profile under the “Push Notifications” section by toggling the switch. The system will automatically update the push notification settings and functionality once the toggle is switched.

International Transfer of Personal Information

Iron Pulse is headquartered in the United States, and our service providers operate in the United States and around the world. As a result, your personal information may be transferred to the United States and other countries or regions with data protection and privacy laws that differ from those of your country of residence.

When we transfer your personal information outside your country of residence, we do so in compliance with applicable laws and take appropriate measures to protect your information. However, please note that outside your jurisdiction of residence, your personal information will be subject to the laws of the applicable local jurisdiction, which may allow foreign governments, courts, law enforcement, or regulatory agencies to access your information under certain circumstances.

By using the Services and/or providing Iron Pulse with access to your personal information, you acknowledge that your personal information may be transferred to countries outside your country of residence.

User-Generated Content

We may offer publicly accessible interactive features (such as the creation of public challenges). Any information you post in any public section of the Services may be accessible to all participants, regardless of their location. By posting information via such interactive features, you acknowledge and agree that you have no expectation of privacy or confidentiality for content you submit through these features, regardless of whether it contains your personal information. For more details on how this information is used, see the “Content Ownership and Use” section (“Our License to You” and “Your License to Us”) in our Terms of Service.

How We Protect Your Information

We maintain reasonable technical, organizational, and administrative security measures designed to protect personal information under our control from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please note that, despite our efforts, no security measures can guarantee absolute security.

How We Retain Your Information

We will retain your personal information for as long as necessary to fulfill the purposes outlined in this Policy (including meeting our legal, accounting, or reporting obligations), unless a longer retention period is required or permitted by law.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process your personal information; whether we can achieve those purposes through other means; and applicable legal requirements.

If we de-identify information, we will maintain and use it in a de-identified form and will not attempt to re-identify it, except as permitted by law.

Contact Us

If you have any questions or concerns regarding this Policy or our privacy practices, you may contact us at support@ironpulse.com or at:

Your Privacy Rights

Depending on your place of residence, the laws of your state may grant you certain privacy rights regarding how your personal information is collected, stored, used, and shared, including:

• Right to Access and Data Portability – The right to confirm whether we process your personal information, to know with whom we share it, and to access or obtain a copy of your personal information in a portable and, to the extent technically feasible, readily usable format.
• Right to Deletion – The right to request the deletion of your personal information (subject to certain exceptions provided by applicable law).
• Right to Correction – The right to request the correction of inaccuracies in your personal information, considering the nature of the information and the purposes for which we process it.
• Right to Restrict or Opt-Out of Certain Processing – This includes:
  • Opting out of the use of push notifications in the system.
  • Restricting the processing of your personal information for purposes of obtaining accurate calculations of your physical activity.
• Right to Consent to Processing of Sensitive Information – Certain states grant residents the right to consent to the use of sensitive information. In this case, it means that we cannot use sensitive information (beyond providing our Services) without your consent.
• Right to Non-Discrimination – We will not discriminate against you for exercising your legal rights.
• Right to Appeal Decisions – You may have the right to appeal a decision regarding your privacy rights request. To appeal such a decision, send your request to support@ironpulse.com with “APPEAL” in the subject line.

How to Exercise Your Rights

• You can email us at support@ironpulse.comwith “Rights Request” in the subject line. In the body of the email, please include the state in which you reside, your Apple ID, and details about which rights you wish to exercise.
• Submitting a Request via an Authorized Agent. Where permitted by law, you may submit requests through an authorized agent or representative by emailing support@ironpulse.com. To process such requests, we will need to verify the identity of the agent and confirm that you have authorized them to act on your behalf.
• Questions. If you have any questions or complaints about our handling of your personal information, you may contact us at support@ironpulse.com.