# Privacy Policy for SportKommando and Motivoice
Last Updated: June 21, 2026
Welcome to SportKommando! We are committed to protecting your privacy and ensuring a secure, high-performance experience. This Privacy Policy explains how we collect, use, safeguard, and commercially leverage your information across our website (**SportKommando**, available at www.sportkommando.com) and our mobile application (**Motivoice**).
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## 1. Controller Information
The responsible party for data processing (the „Controller“) under the General Data Protection Regulation (GDPR) is:
**Marvin Dietrich**
Gertrud-Bollenrath-Weg 1
50765 Cologne, Germany
Email: support@maleebu.com
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## 2. Types of Data We Collect
To calibrate your coaching, power social features, manage in-app transactions, and optimize our systems, we collect and process a wide variety of data across our platforms.
### a) Sensitive Health, Biometric & Psychological Data (Motivoice App)
Under Article 9 of the GDPR, we process „Special Categories of Personal Data“ to create your customized coaching profile:
* **Biometrics:** Height, weight, target weight, age/birthdate, and gender.
* **Performance Metrics:** Activity frequency, session duration, daily commitments, and „Neural Streak“ (consistency tracking).
* **Workout & Training Details:** Training type, dates, exercises, sets, reps, weights used, and goal achievement speeds (steady, balanced, or intense).
* **Psychological Profiling (Mind-Vault):** We process your „Goals,“ „Demons“ (fears, failures, and mental barriers), and „Anchors“ (sources of motivation and personal values) to tailor real-time AI interactions. Mind-Vault entries may be end-to-end encrypted (AES-256) on your device before cloud synchronization.
* **Voice & Audio Data:** If you use Voice Mode, we process audio recordings, vocal patterns, and spoken responses to generate transcripts and formulate real-time AI coaching dialogs.
### b) Social, Community & Squad Data (Motivoice App)
To facilitate social interaction and group motivation, we process:
* **Profile Details & Connections:** Display name, profile pictures, unique user IDs, friends lists, and active friend requests.
* **Squad Data:** Squad names, custom mottos, administrator roles, membership lists, and invite/join codes.
* **Chat Messages:** Text messages, media attachments, sender IDs, and timestamps sent within Squad chat rooms.
* **Shared Goals:** Collaborative missions, group goal descriptions, participant rosters, and shared progress logs.
### c) Personal, Technical & Transactional Data (Motivoice App)
* **Registration:** Email address, display name, and third-party authentication data (Google/Social Login).
* **Transaction Data:** Purchases of „VoiceCoins“ or subscriptions, transaction records, and token balances, processed securely via RevenueCat, Apple App Store, and Google Play Store.
* **Automatic Logs & System Metrics:** Anonymized IP addresses, device model, operating system version, app version, local settings, and device performance tier (monitored to scale down intensive rendering/animations).
### d) Website-Specific Data & Media (SportKommando Website)
* **Comments:** When visitors leave comments on the site, we collect the data shown in the comments form, the visitor’s IP address, and browser user agent string to aid spam detection.
* **Gravatar:** An anonymized string (hash) created from your email address may be provided to the Gravatar service to verify profile image usage (see Gravatar Privacy Policy).
* **Media Uploads:** If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS). Visitors to the website can download and extract any location data from these images.
### e) App Store Privacy Nutrition Labels & CCPA Compliance
Pursuant to Apple App Store and Google Play Store requirements, we provide complete transparency regarding the specific data types collected by Motivoice. This privacy policy serves as the basis for our **“Privacy Nutrition Labels“** displayed on the respective app stores. Under the California Consumer Privacy Act (CCPA) and other state regulations, failing to list or inaccurately listing these data types—including those processed by third-party analytics and tracking integrations—is a violation of our commitment to you and may expose the application to severe legal liabilities.
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## 3. How We Use Your Data & AI Content Generation
We process your data to power the core services of Motivoice and SportKommando:
* **AI Coaching & Voice Synthesis:** Using Large Language Models (LLMs), Speech-to-Text, and Text-to-Speech engines to provide personalized, real-time coaching interactions.
* **Mind-Vault Integration:** Persisting and indexing your psychological parameters (goals, demons, anchors, styles) so your chosen guides can adapt to your mental state.
* **Social & Engagement Features:** Managing friend networks, leaderboard rankings, Squad chats, and collaborative missions.
* **Gamification & System Access:** Tracking and debiting VoiceCoin balances during active coaching sessions.
* **Website Integrity:** Utilizing automated spam detection for comments left on the SportKommando website.
### Critical AI Disclosure (FTC & Regulatory Compliance)
> [!IMPORTANT]
> **Motivoice is AI-generated and can make mistakes. This is not a therapeutic recommendation and is solely for self-help and entertainment.**
>
> In accordance with the US Federal Trade Commission (FTC) guidelines regarding AI transparency and deceptive advertising, we explicitly disclose that all interactive coaching monologues, fitness recommendations, and reflective responses are generated by Artificial Intelligence.
>
> All coaching dialogue, motivational monologues, exercise plans, and psychological advice are generated dynamically by artificial intelligence models. They do not constitute professional medical, psychological, or athletic training advice. Always consult a certified professional before beginning any intense training regimen.
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## 4. Sale and Commercial Disclosure of Data to Third Parties
> [!WARNING]
> **Data Commercialization & Monetization Disclosure:**
>
> We reserve the right to sell, rent, lease, license, trade, disclose, or transfer your collected data—including but not limited to your fitness performance metrics, profile details, workout history, goals, and technical data—to external third parties (such as data brokers, advertising networks, commercial marketing agencies, corporate sponsors, and research institutions) for financial, marketing, targeting, or profiling purposes.
>
> By registering an account and using the Motivoice application, or interacting with the SportKommando website, you explicitly consent to the sale, licensing, and commercial distribution of your data to these external third-party buyers.
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## 5. User Responsibility, Content Liability & Copyright Compliance
> [!CAUTION]
> **User-Generated Content & Stored Data Liability:**
>
> You are solely and exclusively responsible for any and all content, text, transcripts, voice recordings, media, images, or other data that you upload, transmit, sync, input, or store in the Motivoice application or on the SportKommando platform.
>
> We assume absolutely no liability or responsibility for any copyrighted material, proprietary information, illegal files, prohibited contents, or otherwise unlawful data you choose to store on our servers or process through our services. The responsibility to ensure compliance with intellectual property rights, copyright laws, and standard regulations rests entirely and solely on you as the user. You agree to fully indemnify and hold SportKommando, Motivoice, and its operators harmless from any claims, damages, or legal actions resulting from data or materials you submit.
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## 6. Legal Basis for Processing
We process data in accordance with the GDPR:
* **Consent (Art. 6(1)(a) & Art. 9(2)(a) GDPR):** For processing sensitive health data, voice recordings, psychological profiles in the Mind-Vault, and for the commercial sale of your data to third parties.
* **Contract (Art. 6(1)(b) GDPR):** To provide the coaching features, manage your account, and process subscriptions and VoiceCoin purchases.
* **Legitimate Interests (Art. 6(1)(f) GDPR):** To detect spam, monitor app performance tiers, and maintain platform security.
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## 7. International Data Transfers (USA & Third Countries)
The infrastructure powering the SportKommando website and the Motivoice app is hosted on servers located in the United States and other global regions:
* **Google Cloud & Firebase:** For databases, storage, authentication, and analytics.
* **AI Services (e.g., OpenAI, Anthropic, Google Gemini, Groq):** For AI reasoning, transcripts, and voice generation.
* **RevenueCat:** For in-app purchase validation and subscription tracking.
*Data protection laws in the USA and other non-EU countries may offer a lower standard of protection than the GDPR. By granting your explicit consent during onboarding and registering your account, you agree to the transfer of your data to these third parties pursuant to Art. 49(1)(a) GDPR.*
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## 8. Cookies, Tracking & Third-Party Analytics
* **Motivoice App:** We use local storage and secure device vaults (e.g., Expo Secure Store) to maintain active login sessions, save offline preferences, and encrypt local Mind-Vault states.
* **Third-Party Analytics & Advertising Conversion (GA4 & Meta Pixels):** To optimize application performance, monitor stability, and track our digital campaigns, we integrate tracking tools including **Google Analytics 4 (GA4)** and the **Meta Pixel**. These services collect device identifier tokens, cookie identifiers, interaction patterns, and conversion markers. We declare these tools to fulfill CCPA, GDPR, and App Store Privacy Nutrition Label guidelines.
* **SportKommando Website:**
* **Comment Cookies:** If you leave a comment, you may opt-in to saving your name and email in cookies (valid for 1 year).
* **Session Cookies:** Temporary cookies are used to track login status and browser compatibility.
* **Embedded Content:** Articles on the site may contain embedded content (e.g., YouTube videos, social media posts). These external platforms may collect data, use cookies, and track your interactions.
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## 9. Data Retention
* **Active Accounts:** We retain your profile data, Mind-Vault entries, and training logs as long as your account is active.
* **Inactivity & Archival:** Accounts that remain inactive for more than 24 months may be archived or deleted.
* **Website Comments:** Comments and their associated metadata are retained indefinitely to verify follow-up comments automatically.
* **Account Deletion:** You can request account deletion via the app settings. Your personal data will be deleted or irreversibly anonymized within 30 days of the request, subject to our right to retain commercialized/anonymized data sets already shared with third parties.
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## 10. Your Rights
Under the GDPR, you have the following rights:
* **Access & Rectification:** The right to inspect and correct your data.
* **Erasure & Restriction:** The right to request the deletion of your personal data („Right to be forgotten“) or restrict its processing.
* **Consent Withdrawal:** The right to withdraw your consent for future voice processing or health profiling at any time via settings.
* **Opt-Out of Data Sales:** Depending on your jurisdiction (e.g., EU GDPR, California CCPA), you may have the right to opt-out of the sale of your personal information. You can manage this preference within the settings of the Motivoice app.
To exercise any of these rights, contact us at: **support@maleebu.com**.
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## 11. Security & Regulatory Compliance
We employ industry-standard encryption protocols (such as AES-256 for local Mind-Vault entries and TLS for all API transmissions) to protect your health, psychological, and performance data from unauthorized access, loss, or alteration.
### FTC Civil Penalties Notice:
> [!CAUTION]
> We maintain a strict data security program. Users and regulators are notified that we take data security compliance seriously. Under the rules of the US Federal Trade Commission (FTC), companies are subject to severe civil penalties of up to **$53,088 per violation** for privacy policy violations and data security breaches. We align our security and privacy practices with these standards to ensure our compliance.
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## 12. Changes to this Policy
We may update this Privacy Policy from time to time to reflect changes in our data processing practices or commercial partnerships. We will notify you of any significant updates via an in-app alert or email. The current version will always be accessible at www.sportkommando.com.