Application Privacy Policy

Effective from October 1, 2021

At Softroids sp. z o.o. based in Wrocław (50-555), at ul. Krynicka 8/10 („Softroids”), we take your privacy seriously and we care about ensuring that your personal data, which we process in connection with your use of the Iron Kegel application, are properly protected.

This Privacy Policy („Privacy Policy”) of the Iron Kegel Application („Application”) has been developed by us to inform you as a user of the Application („User”), to what extent the use of the Application requires us to process your personal data, what it involves, when these data may be disclosed to external entities, what rights you have in relation to their processing, and how we store and protect your personal data.

Personal Data Administrator

Softroids determines the manner and purposes of using the personal data collected about you, so it is referred to as the „Administrator”.

The personal data administrator is Softroids limited liability company based in Wrocław (50-555), at ul. Krynicka 8/10, entered into the Register of Entrepreneurs kept by the District Court Wrocław – Fabryczna, 6th Commercial Division of the National Court Register under the number KRS: 0000881847, NIP: 8992892803, REGON: 388087871, with a share capital of PLN 5,000.00.


If necessary, we will answer all your questions related to the Privacy Policy. Contact with the Administrator is possible via the e-mail address or the correspondence address ul. Krynicka 8/10, 50-555 Wrocław. You can also contact us to exercise the rights you have under this Privacy Policy, including to delete your personal data.

Your rights

In connection with the processing of your personal data, you have the right to request from Softroids:

  1. access to your personal data;
  2. obtaining a copy of the data;
  3. rectification of data: in the case where the data is incorrect or incomplete;
  4. deletion of data: in the case where the data is no longer necessary for the purposes for which it was collected by Softroids; the data is processed unlawfully; you object to the processing of data; the data should be deleted to comply with a legal obligation;
  5. restriction of data processing: in the case where the accuracy of the data is questioned – for a period allowing Softroids to verify the accuracy of your data; the data is processed unlawfully, but you do not want the data to be deleted; your data is no longer needed by Softroids, but may be needed by you to establish, pursue or defend claims; or in the case where you object to the processing of data – until it is determined whether legally justified grounds override the basis of the objection;
  6. transfer of data to another administrator: in the case where the data is processed automatically in connection with a concluded contract.

In addition to the above rights, you also have the right to object to processing to the extent that this processing takes place on the basis of a legitimate interest, and the objection is justified by a particular situation, and you also have the rightto lodge a complaint with the supervisory authority in connection with the processing of your personal data by Softroids to the President of the Office for Personal Data Protection (ul. Stawki 2, 00-193 Warsaw).

If you want to exercise your rights, indicated above or believe that our processing of your personal data violates applicable law, please contact us at the addresses indicated above in the „contact” section.

Usually, we do not charge for the use of rights. However, if the request is clearly unjustified, repetitive or excessive, in accordance with the law, we may charge a reasonable fee or refuse to fulfill the request.

Data deletion

The Iron Kegel application does not store user data on the server, so data deletion by Softroids is not possible.

Personal data we collect

The Administrator makes every effort for you to provide only those data that are necessary to fully use the functionality of the Application.

If you decide to contact us, you will provide us with some personal data from your email or traditional correspondence.

If you decide to file a complaint in connection with your use of the Application, Softroids may process your personal data contained in the complaint for its consideration, in particular your contact details (name, surname, correspondence address or email).

Nature of providing personal data

Providing personal data when registering an account is voluntary, but necessary for you to use the Application. Providing other data indicated above while using the Application is also voluntary, but necessary to fully use the functionality of the Application after purchasing a subscription.

In the case of contact or filing a complaint, providing personal data is voluntary, but necessary to properly resolve the matter, answer the question, consider the complaint.

If required by law, we may require you to provide other necessary data.

Data usage

Your personal data will be processed for the following purposes:

  • providing services in connection with the Application in terms of providing content, managing accounts, storing data, including considering complaints. The legal basis for processing is the necessity of processing to conclude and perform service contracts, license agreements (Article 6 (1) (b) of the GDPR);
  • conducting correspondence and answering asked questions. The legal basis for processing is the legitimate interest of the Administrator (Article 6 (1) (f) of the GDPR) consisting in the necessity to resolve the matter or provide an answer;
  • consideration of complaints. The legal basis for processing is the legitimate interest of the Administrator (Article 6 (1) (f) of the GDPR) consisting in the necessity of proper consideration of the complaint;
  • determination and pursuit of claims or defense against them. The legal basis for processing is the legitimate interest of the Administrator (Article 6 (1) (f) of the GDPR) consisting in the protection of his rights;
  • analytical and statistical. The legal basis for processing is the legitimate interest of the Administrator (Article 6 (1) (f) of the GDPR) consisting in conducting statistics and analyzing inquiries submitted by Users via the Application in order to improve its functionality;
  • UxCam Session Tracking – We use a third-party service called UxCam to record and analyze user sessions within the Iron Kegel application. UxCam helps us understand how users interact with the app, identify usability issues, and improve the overall user experience. The data collected by UxCam may include screen views, actions performed within the app, and other behavioral metrics. This data is stored and processed by UxCam in accordance with their privacy policy, which you can review here. The legal basis for this processing is our legitimate interest in improving the functionality and usability of the Iron Kegel application (Article 6 (1) (f) of the GDPR).

Data storage

  • In connection with the applicable legal regulations, Softroids must ensure that the data in its possession is correct and up-to-date. In accordance with the principle of limiting storage, we cannot store your data indefinitely. For these reasons,if you cancel your subscription (terminate the contract), which results in the loss of access to the Application and all data saved in it, this data will be automatically deleted by us within 12 (twelve) months from the last day of the subscription validity, unless during this time you repurchase access to the Application (Application subscription) within the same User account. Retrieving the data you previously entered into the Application will not be possible after this time.
  • Selected personal data may be processed by Softroids after the above time for the purpose of establishing, pursuing or defending potential claims, for the period resulting from the limitation of these claims.
  • We apply rational technical and organizational actions aimed at ensuring the security of the collected data in accordance with the applicable standards, including the use of electronic security systems and password protections to protect against unauthorized access.

Disclosure of personal data

  • Sometimes we need external entities to perform services for us. In connection with this, the recipients of your personal data may be entities cooperating with Softroids providing IT, hosting services, as well as postal operators and other entities to the extent necessary to achieve the purposes of data processing.
  • We may also disclose your data in cases required by law, and also in order to establish, exercise or defend our rights.
  • Since the fee for using the mobile application is collected by the Google Play or App Store operator, the User regulates all due payments related to the purchase using an account set up with one of the above operators, i.e. Google Ireland Limited based in Ireland or Apple Distribution International based in Ireland. Your use of these accounts to make payments does not require us to process your personal data. The terms of use of the Google Play or App Store, as well as the rules for processing personal data provided in connection with the purchase of access to the Application have been determined by the operators of these stores (regulations are available at: and; and privacy policies: and, ldl=pl.
  • We inform that the level of personal data protection outside the European Economic Area („EEA”) differs from that provided by European law. For this reason, the Administrator transfers personal data outside the EEA only when it is necessary and with the assurance that your right to privacy is respected. In such cases, the transfer to a third country most often takes place through: cooperation with entities processing personal data in countries in relation to which an appropriate decision of the European Commission has been issued regarding the determination of an adequate level of personal data protection; using standard contractual clauses issued by the European Commission.

Policy Changes

  • The privacy policy is constantly reviewed and updated as necessary. When we make changes, we will provide a new version of the Privacy Policy in the Application and on the Website.