⚠️ Draft — pending legal review. This document is a comprehensive starting point drafted from Traileo's actual data practices. It must be reviewed by qualified counsel and its bracketed placeholders completed before it is relied upon.

Privacy Policy

Last updated: 5 July 2026

This Privacy Policy explains how Codewen Inc ("Codewen", "we", "us", or "our") collects, uses, shares, and protects your personal information when you use the Traileo mobile application and related services (the "Service"). Codewen Inc is the data controller for the personal data described here.

If you have questions, contact us at privacy@traileo.earth or by post at Codewen Inc, [POSTAL ADDRESS TBD].

1. Summary

2. Who this Policy applies to

The Service is intended for users aged 16 and over. It is not directed to children under 16, and we do not knowingly collect their personal data (Section 11).

3. Information we collect

3.1 Information you provide

3.2 Information generated by using the Service

3.3 Information from third parties

4. How we use your information

5. Legal bases for processing (EEA/UK)

6. How we share information

We do not sell your personal data. We share it only as described here.

6.1 With other users

Content you make public — published trails, your public profile, leaderboard standings, and activity you share with connections — is visible to other users according to your visibility settings (including Ninja Mode and per-trail visibility).

6.2 With service providers (sub-processors)

ProviderPurposeData involved
Google LLC — Firebase / Google CloudAuthentication, database, file storage, cloud functions, push messagingAccount, profile, content, location tracks, diagnostics metadata
Apple Inc.Sign in with Apple; App Store subscription billing; push deliveryAuthentication identifiers; subscription/payment (held by Apple)
RevenueCat, Inc.Subscription and entitlement managementSubscription status, purchase history, app user identifier
Mapbox, Inc.Map tiles, trail/place search and geocodingMap interactions and search queries; approximate location for results
Functional Software, Inc. (Sentry)Crash and error diagnosticsTechnical diagnostic and crash data
Google — Sign-InGoogle authenticationGoogle account identifier and email you authorize

6.3 Legal and safety

We may disclose data where required by law, to enforce our Terms, or to protect the rights, safety, and security of Codewen, our users, or the public.

6.4 Business transfers

If Codewen is involved in a merger, acquisition, or asset sale, personal data may be transferred as part of that transaction, subject to this Policy.

7. International data transfers

Our providers may process and store data in the United States and other countries. Cloud Functions and certain processing are configured for the European region where feasible. Where personal data is transferred outside the EEA/UK, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses.

8. Data retention

We retain personal data for as long as your account is active or as needed to provide the Service. When you delete your account in the app, we delete your profile and associated personal data, including recorded tracks, saved-trail library, uploaded images, live-recording data, and statistics, and we remove your references from other users' social graphs. Some data may be retained for a limited period where required for legal, security, fraud-prevention, or backup purposes, then deleted or anonymized.

9. Your rights

Depending on where you live, you may have the right to access, rectify, erase, restrict, or object to processing of your personal data, to data portability, and to withdraw consent. You can edit most profile data and delete your account in the app. EEA/UK users may also lodge a complaint with their local data protection authority. To exercise a right, use the in-app controls or contact privacy@traileo.earth.

10. Security

We use industry-standard measures including encryption in transit (TLS), authenticated access, and server-side access-control rules. No method of transmission or storage is completely secure, but we work to protect your information and continuously improve our safeguards.

11. Children

The Service is not directed to and may not be used by anyone under 16. We do not knowingly collect personal data from children under 16. If you believe a child has provided us personal data, contact privacy@traileo.earth and we will delete it.

12. Push notifications & permissions

We request iOS permissions for location (to record rides, including in the background), notifications, and camera/photo library (to add profile and trail images). You control each permission in iOS Settings; denying one disables that feature but not the rest of the app.

13. No advertising or cross-app tracking

Traileo contains no advertising, integrates no advertising or analytics-tracking SDKs, and does not access the iOS advertising identifier (IDFA) or request App Tracking Transparency permission. We do not build cross-app or cross-site profiles of you.

14. Changes to this Policy

We may update this Policy from time to time. When we make material changes, we will update the "Last updated" date and, where appropriate, notify you in the app. Continued use after changes take effect constitutes acceptance.

15. Contact

Codewen Inc
Email: privacy@traileo.earth
Post: [POSTAL ADDRESS TBD]