Last updated: August 29, 2026
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Tomera is a cycle-adaptive strength training app developed by Emilia Radmacher (sole proprietor).
Controller under Art. 4(7) GDPR:
Emilia Radmacher Dietramszeller Str. 4 81371 München Germany
Email: privacy@tomera.app
Tomera is built on a simple principle: your training and health data stays on your device. Your workout data, cycle data, symptom reports and training history are stored locally on your iPhone using Apple's Core Data framework. We operate no server that holds them, and they do not leave your device unless you explicitly choose to export or share them.
A small amount of data does leave your device: anonymous usage counts, and anything you actively choose to send us, such as feedback or your email address. Section 5 lists every one of these, and none of them contains health or cycle data.
All of the following is stored exclusively on your device:
Profile information: Your first name, training goals, equipment preferences, and unit preferences (metric/imperial). This data is entered during onboarding and used to generate your training program.
Cycle data: If you choose to enable cycle tracking, Tomera stores your cycle type, last period start date, cycle length, period length, and adaptation preference. This data is used to estimate your current cycle phase and adapt your training accordingly. It is collected only after you give explicit consent during onboarding. If you decline, none of it is stored.
Symptom and check-in data: If you enable cycle tracking, Tomera stores the symptoms and energy levels you report at pre-session check-in and when logging your period. This is health data and is collected under the same explicit consent as your cycle data. If you decline that consent, none of it is stored.
Workout data: Completed workout sessions, including exercises performed, sets, reps, weight used, RPE (rate of perceived exertion) ratings, rest periods, and session duration.
Progression data: Training decisions computed by the progression engine, including weight and rep adjustments, deload decisions, and cycle-phase adaptations with their explanations.
Consent record: The date and version of the privacy policy you consented to, so we can tell you what you agreed to and when.
Profile and workout data: processed on the basis of contract performance (Art. 6(1)(b) GDPR). This data is necessary to generate and adapt your training program, which is the service you signed up for.
Cycle data, symptom reports and check-in health data: this is health data and counts as a special category under Art. 9(1) GDPR. It is processed only on the basis of your explicit consent (Art. 9(2)(a) GDPR), which you give during onboarding before any of it is collected. If you decline, none of it is stored and the app works without it.
You can withdraw this consent at any time in Settings. Withdrawal deletes all stored cycle and symptom data and does not affect the lawfulness of processing carried out before withdrawal.
Anonymous usage statistics: processed on the basis of our legitimate interest (Art. 6(1)(f) GDPR) in understanding whether the app's setup and subscription screens work. Section 5 describes exactly what is measured and why it cannot be traced back to you.
Feedback submissions and email sign-up: processed on the basis of your consent, given by choosing to submit (Art. 6(1)(a) GDPR).
Very little, and none of it is health or cycle data. There are five cases:
Anonymous usage statistics: Tomera counts how many people complete each step of onboarding and each step of the subscription screen, so we can find the places where the app is confusing or broken. These counts are processed by TelemetryDeck, a German analytics provider hosting its data in the EU.
What is sent: the name of the screen or step reached, and standard technical values such as app version, iOS version and device model. What is never sent: your cycle data, your symptoms, your phase, your workouts, your name, your email address, or any identifier that persists.
To count a sequence of steps as one visit rather than several, each event carries a random value generated fresh every time the app starts. It is held in memory only, never saved to your device, and is gone when you close the app. It is not derived from your device, your Apple Account or anything you entered, it appears nowhere else, and there is no way to connect it to you or to any other data Tomera holds. Because of this we cannot identify which statistics came from you, and therefore cannot individually retrieve or delete them (Art. 11(2) GDPR).
Your email address, if you give it: You may optionally give us your email address to hear about updates. This is entirely voluntary, it is never required, and the app is fully usable without it. Email addresses are held by Brevo, an email provider based in the EU.
Your email address is stored separately from everything else and is never connected to your training data, cycle data or usage statistics. We have no way to link an email address to an app installation. You can unsubscribe at any time using the link in any email we send, which deletes your address from our list.
Feedback submissions (optional): Submitting feedback or contacting Support is voluntary. If you do submit, your message is sent to a Google Form operated by the developer along with diagnostic metadata (app version, iOS version, device model, locale, workout count, days since first launch). For Support submissions, you may optionally include your email for a reply. This data is used solely to improve the app and respond to inquiries.
The form is operated by Google LLC (USA). Submitting feedback therefore transfers your message and the listed diagnostic data to the United States. Google LLC is certified under the EU-US Data Privacy Framework, which the European Commission recognises as providing an adequate level of protection. Submitting feedback is entirely voluntary and the app is fully usable without it.
Purchases (Apple): Subscriptions are processed entirely by Apple through the App Store. Tomera never receives or stores your payment details, billing address, or Apple Account information. The app only receives an anonymous confirmation of whether an active subscription exists. Apple's handling of purchase data is governed by Apple's privacy policy.
Crash reports (Apple): If the app crashes, Apple may collect standard crash diagnostics as part of iOS. This is governed by Apple's privacy policy and your device settings, not by Tomera. Tomera adds no crash reporting tool of its own.
TelemetryDeck (Germany, hosted in the EU): anonymous usage counts. No health data, no persistent identifier.
Brevo (EU): your email address, and only if you choose to give it.
Google LLC (USA, EU-US Data Privacy Framework): feedback messages you choose to send, with the diagnostic metadata listed in §5.
Apple: subscription status and crash diagnostics, governed by Apple's privacy policy.
No other party receives any data. Your cycle data, symptom reports, workouts and training history are received by nobody, because they never leave your device.
Right to access: You can export all your data at any time via Settings → "Export Data". This produces a JSON file with your profile, your cycle and symptom logs, your pain records, your training plan and your full workout history. A small number of internal records, including Tomera's own log of each training decision, are not yet part of the file. A future update will add them.
Right to rectification: You can correct your profile, cycle, and training data at any time in Settings.
Right to erasure: You can delete all your data at any time via Settings → "Delete All Data". This permanently removes all data from your device. Since Tomera stores none of it externally, deletion is complete and irreversible. To remove your email address, use the unsubscribe link in any email we send.
Right to restriction: You can disable cycle adaptation in Settings. Your cycle data is then no longer used to modify your training, while the data itself remains stored.
Right to data portability: The JSON export format allows you to take your data to any other service.
Right to object: You can disable cycle adaptation at any time in Settings without deleting your data.
Right to withdraw consent: You can withdraw your consent to cycle and symptom data processing at any time in Settings. This deletes all stored cycle and symptom data.
On usage statistics: as described in §5, the anonymous usage counts carry no identifier that persists or that can be linked to you, so we are unable to locate, retrieve or delete the statistics originating from any particular person (Art. 11(2) GDPR). Equally, they cannot be used to learn anything about you.
If you believe your data has been handled unlawfully, you have the right to complain to a supervisory authority. The authority responsible for us is:
Bayerisches Landesamt für Datenschutzaufsicht (BayLDA) Promenade 18 91522 Ansbach, Germany Postal address: Postfach 1349, 91504 Ansbach Phone: +49 981 180093-0 Email: poststelle@lda.bayern.de Web: https://www.lda.bayern.de
You may also lodge a complaint with the supervisory authority in your own country of residence.
On your device: your data persists for as long as the app is installed. Deleting the app removes all of it. There is no cloud backup of Tomera data unless you have enabled iCloud device backups through Apple (which is governed by Apple's privacy policy).
Usage statistics: retained in aggregate by our analytics provider. They contain no persistent identifier, so they cannot be attributed to any individual at any point.
Your email address: retained until you unsubscribe or ask us to remove it.
Feedback submissions: retained for as long as needed to respond and to act on the feedback.
Tomera is not directed at children under 16. We do not knowingly collect personal information from children under 16.
We may update this privacy policy from time to time. The updated version will be accessible within the app under Settings → "Privacy Policy". Material changes will be noted in the app's update notes.
For questions, concerns, or data requests:
Emilia Radmacher Dietramszeller Str. 4 81371 München Germany
Email: privacy@tomera.app