The processing of personal data through the TourenUp App is managed by Denis Bondar, a sole proprietor incorporated in Luxembourg (“TourenUp,” “we,” “us,” or “our”). As the Data Controller, we are responsible for determining the purposes and means of processing personal data through our app. Our commitment is to handle your personal data with utmost care and transparency, ensuring compliance with applicable regulations, including but not limited to Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation - GDPR) and Luxembourg’s data protection laws.
Contact Information:
Company Name: Denis Bondar
Contact Person: Denis Bondar
Email: denis@touren.tech
Website: https://www.touren.tech/
TourenUp collects and processes personal data to deliver a skills assessment and credential platform. The data we collect depends on your interaction with the app and includes the following categories:
Account Information: Personal details such as your name, email address, username, and profile photo, required to manage your account and enable interaction with other users.
Motion and Sensor Data (Health Data): Inertial measurement unit (IMU) data including accelerometer, gyroscope, and magnetometer readings, captured at 10 Hz during drill attempts. This data is used exclusively to compute objective skill scores for your Skills Passport — including tilt stability, throttle smoothness, braking performance, and body balance metrics. This data is classified as Health Data under applicable regulations due to its physical activity nature. It is never sold to third parties and is not used for advertising or profiling unrelated to skill assessment.
GPS and Location Data: Real-time GPS coordinates and trail position data captured during drill attempts, used to verify attempt location against declared terrain type, compute speed and distance metrics, and cross-validate telemetry scores. Location data is retained per the retention schedule below and is not shared with marketing partners.
Video Data: Video recordings of drill attempts submitted voluntarily by riders, used for human coach review and body position scoring. Video files are stored securely and reviewed only by verified TourenUp coaches for the purpose of skill assessment validation. Video is never used for facial recognition or identity verification.
Coach Validation Records: Records of coach verdicts on individual drill attempts, including label classifications and confidence ratings, used to produce validated training data for the scoring engine and to issue Skills Passport credentials.
Activity Data: Routes recorded, drill attempts completed, scores achieved, and progression history, used to generate your Skills Passport credential and provide skill gap analysis.
Device Information: Device type, operating system, unique device identifiers, IP address, and app settings, used to optimise app performance and ensure secure account access.
Usage Data: Pages visited, features accessed, and settings configured, used to understand user behaviour and improve the app.
Legal Basis for Processing
Performance of a Contract: Processing motion/sensor data, GPS data, and video data is necessary to provide the core skill assessment service you have requested.
Legitimate Interest: Processing activity, usage, and device data supports our interest in improving services, ensuring app security, and enhancing user experience.
Consent: We obtain your consent for optional processing such as personalised marketing or location data access beyond drill sessions, where required by law.
2a. Health Data- Specific Disclosures Google Play and applicable data protection regulations require explicit disclosure of Health Data collection. TourenUp collects the following data categories that fall within the Health Data classification:
Physical activity telemetry: Accelerometer, gyroscope, and magnetometer data reflecting body movement and balance during motorcycle riding drills.
Motion-derived fitness metrics: Computed metrics including tilt angle, jerk, pitch trend, correction rate, and speed variance, derived from raw IMU data to assess physical riding skill.
This data is:
- Collected only during active drill recording sessions, with your explicit initiation of each session
- Used solely for skill scoring, Skills Passport credential generation, and coach validation
- Stored on secured cloud infrastructure with access restricted to verified coaches and platform engineering
- Never sold, licensed, or shared with insurers, advertisers, or third parties without your explicit consent
- Retained for the duration of your account and deleted within 90 days of account deletion upon request
You may request export or deletion of all Health Data at any time by contacting denis@touren.tech.
TourenUp may share your personal data with third-party service providers to support our operations, including:
Cloud Storage Providers: For secure data storage and management.
Analytics Providers: To analyze app usage patterns and optimize services.
Customer Support Services: To assist with user queries and issue resolution.
Marketing Partners: To send promotional content or advertisements, with your consent.
We ensure these third parties comply with GDPR and Luxembourg’s data protection laws, using safeguards like standard contractual clauses for data transfers outside the European Economic Area (EEA).
As a user, you have the following rights regarding your personal data:
Right to Access: Request access to the personal data we hold about you.
Right to Rectification: Correct inaccurate or incomplete personal data.
Right to Erasure: Request deletion of your personal data when no longer necessary or under certain conditions.
Right to Restrict Processing: Request restriction of data processing in specific situations, such as when contesting data accuracy.
Right to Data Portability: Receive your personal data in a structured, commonly used, machine-readable format for transfer to another controller.
To exercise these rights or withdraw consent, contact us at denis@touren.tech. We will respond within the timeframe required by applicable laws, typically within one month.
We retain personal data only as long as necessary for the purposes collected or as required by law: Account Information: Retained while your account is active; deleted within a reasonable period after account deletion, except for legal or regulatory requirements.
Activity and Usage Data: Retained to analyze app performance and trends, typically for a limited period.
Location Data: Retained for active sessions or until you disable location services.
Data is securely deleted or anonymized once retention periods expire or when no longer needed.
The TourenUp App uses cookies and similar technologies to enhance user experience:
Essential Cookies: Required for app functionality, non-disableable.
Performance Cookies: Analyze app usage to improve performance.
Personalization Cookies: Store preferences for a customized experience.
Advertising Cookies: Deliver relevant ads and measure effectiveness.
You consent to cookies by using the app but can modify preferences via device settings.
We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, and destruction. These measures include encryption, secure servers, and restricted access controls. We regularly review and update our security practices to ensure the continued protection of your data.
This Privacy Policy may be updated from time to time to reflect changes in our practices, technologies, or legal requirements. The latest version will always be available on our website and within the app. We encourage you to review this policy periodically to stay informed about how we are protecting your personal data.
If we make significant changes to this policy, we will notify you through the app or via email, as appropriate.
If you have any questions, concerns, or suggestions regarding this Privacy Policy or the processing of your personal data, please contact us at:
- Email: denis@touren.tech
We are committed to working with you to resolve any privacy-related issues and appreciate your feedback on our data protection practices.
