Privacy Policy

This Privacy Policy ("Policy") governs how we handle user information in connection with the website "DELT" (https://getdelt.com; the "Site") that we operate, and the iOS application "DELT" (the "App") that we make available on the App Store. In this Policy, "we," "us," or "our" refers to the operator of the Site and the App.

The Site and the App handle data very differently. The Site collects user information through analytics and similar means. The App, by contrast, processes data on the user's device as a matter of principle, and we do not collect the user's information. To convey this distinction accurately, this Policy is divided into "Part 1 — About the Site" and "Part 2 — About the App," with matters common to both consolidated in "Part 3 — Common Provisions."

Part 1 — About the Site (getdelt.com)

1. Scope (Site)

This Part 1 applies to our handling of user information on the Site. The handling of personal data on third-party websites or services linked from the Site is governed by the rules established by those third parties, and we bear no responsibility for it.

2. User Information We Collect

2.1 Access logs and usage information

The following is automatically collected when the Site is accessed.

• IP address
• Browser type and version (User-Agent)
• Referring URL (referrer)
• Date and time of access
• Pages viewed and time spent
• Screen resolution and device type
• Language settings
• Country/region (estimated from IP address)

2.2 Cookies and similar technologies

(1) Strictly necessary cookies and local storage

Used without identifying the individual user and without consent.

• The selected display language (ja / en / ko)
• A record of the user's cookie-consent status

(2) Analytics cookies

Google Analytics 4 is used only where the user has given consent.

• Google Analytics identification cookies such as _ga and _ga_*

2.3 Information provided through inquiries

When a user contacts us at support@getdelt.com, we obtain information such as the email address, name (optional), and the contents of the inquiry.

3. Purposes of Use

We use the user information collected on the Site for the following purposes:

1. To provide, maintain, protect, and improve the Site
2. To analyze how the Site is used and to compile statistical data
3. To respond to inquiries
4. To send important notices concerning the Site
5. To address improper or fraudulent use

4. Provision to Third Parties (Site)

4.1 Provision of personal data to third parties

We do not provide personal data to third parties without the user's consent, except in the following cases:

1. Where disclosure is required by law
2. Where it is necessary to protect a person's life, body, or property and it is difficult to obtain the individual's consent
3. Provision to service providers acting on our behalf (described below)

4.2 Service providers and information-collection modules

We provide data to the following entities for the operation of the Site.

(1) Hosting service

(2) Google Tag Manager

Google Tag Manager is loaded only where the user has consented (see “5. Management of Cookies and Similar Technologies” below).

(3) Google Analytics 4 (web analytics)

Note that information obtained through Google Analytics 4 may be handled by Google LLC in association with personal data. We do not activate this feature unless the user has given consent (see "5. Management of Cookies and Similar Technologies" below).

5. Management of Cookies and Similar Technologies

5.1 Obtaining consent

Analytics cookies and similar technologies (Google Analytics 4), and Google Tag Manager, which loads them, are loaded only where the user has consented through the consent banner on the Site. The default state is that no consent has been given, and until then the Site sends no information to Google. We never obtain consent with a box pre-checked.

5.2 Withdrawing consent

The user may withdraw consent at any time. Consent may be withdrawn as follows:

1. Change the settings via the "Cookie Settings" link on the Site
2. Delete cookies from the browser settings
3. Use the Google Analytics Opt-out Add-on (https://tools.google.com/dlpage/gaoptout)

5.3 Strictly necessary cookies and local storage

Technologies necessary for the basic functions of the Site, such as saving the language setting, are used regardless of whether consent has been given.

6. International Data Transfers (Site)

The Site itself is operated on servers located within Japan (Xserver Inc.), and the majority of user data obtained through the Site is stored within Japan.

However, among the service providers above, Google LLC (the provider of Google Analytics 4 and Google Tag Manager) is located in the United States, and user information obtained via that service may be transferred to and stored in the United States. The laws of the United States concerning the protection of personal data may differ from those of Japan.

To minimize the risks associated with such transfers, we rely on the Standard Contractual Clauses (SCCs) and other safeguards published by Google LLC.

7. Retention Periods (Site)

We retain user information only to the extent necessary to achieve the purposes of use.

• Hosting-server access logs (Xserver): approximately 30 days
• Web analytics data (Google Analytics 4): 14 months
• Inquiry emails: 3 years from completion of the response
• Records of consent status: a reasonable period even after consent is withdrawn

Part 2 — About the App (DELT iOS)

8. How the App Handles Data

The App operates offline as a matter of principle. Workout records, session information, and various settings are stored on the user's device (the automatic backup in 8.4 is also stored in the user's own iCloud Drive) and are not transmitted to or collected by our servers.

8.1 Apple Health integration (HealthKit)

Only where the user enables Apple Health integration (HealthKit) and selects which items to sync, the App syncs the selected items (body weight, body-fat percentage, lean body mass, and waist measurement) bidirectionally (read and write) with Apple Health. If the integration is not enabled, the App does not access Apple Health at all. All data that is read or written is processed and stored only on the user's device and within the user's own Apple Health, is not transmitted to our servers, and is not used for provision to third parties or for tracking.

8.2 Purchases and DELT Founder status

The App has no accounts. Payment for the Purchase (in-app purchase) is processed by Apple's App Store, and we do not receive payment methods or any other payment information. The App checks with Apple, on the device, whether a Purchase has been made. In addition, to determine DELT Founder status (users who recorded their first session before the public release of version 1.0 of the App), the App stores the date and time of the first recorded session on the user's device and in the user's own iCloud. This information is not sent to our servers or to third parties, and we cannot access it.

8.3 Sharing features (image and video export)

Images and videos created with the App's sharing features are generated only on the user's device. They are passed only to the destination the user explicitly selects (such as an SNS app), and only through the user's own action. We do not obtain, transmit, or retain their contents. The handling of data by the destination service is governed by that service's own terms of use and privacy policy.

8.4 Automatic backup (iCloud Drive)

The App keeps one backup per day of the user's records and settings (a ".delt" file) on the user's device, and updates it with the latest records during that day. Where the user has iCloud Drive turned on, the App also saves the same file to the App's folder in the user's own iCloud Drive (iCloud Drive › DELT in the Files app), for restoring on a new device. As a rule, the last 7 days are kept and the App deletes older files. These files are stored in the iCloud of the user's own Apple ID, are not sent to our servers or to third parties, and we cannot access them. The user can view and delete these files in the Files app, and can stop this storage by turning off iCloud Drive for the App in the iPhone Settings.

8.5 Siri and Shortcuts

When the user operates the App from Siri, Shortcuts or Controls (for example starting a workout, completing a set, skipping a rest, or checking the last record for an exercise), the App carries out the action on the device and returns the result to Siri or Shortcuts as words (for example, a confirmation that the set was completed, or the weight and reps from the last session of that exercise). The App also adds the names of the user's routines, with their exercise names, to Spotlight search on the device. How Siri processes what it receives, on the device or on Apple's servers, depends on the Siri and Apple Intelligence features and settings the user uses, and that handling is governed by Apple's Privacy Policy. The App does not send these actions or their results to our servers or to third parties, and we cannot access them.

8.6 Beta (TestFlight)

Beta versions of the App (versions before the official release) are distributed through Apple's TestFlight. To send an invitation email, we register the user's email address (and name, if the user provides it) in Apple's App Store Connect. Through TestFlight, we receive the name and email address of users who join, the feedback and screenshots users send, and, depending on the user's settings, reports when the App quits unexpectedly (including information such as the device model and OS version). We use this information only to distribute and improve the beta and to contact users, and we do not provide it to third parties. Workout, meal, body weight, and other records are never sent through TestFlight. Processing in TestFlight is carried out by Apple, and its handling is governed by Apple's Privacy Policy. To leave the beta or to ask us to delete the email address we registered, please contact us at the address in Section 16.

9. App Store Privacy Disclosure (Data Not Collected)

As described above, because the App's data is processed only on the user's device, within the user's own iCloud, and within the user's own Apple Health, and the responses the App returns to Siri and Shortcuts at the user's request (8.5) are not received by us either, the App qualifies as "Data Not Collected" in the App Store privacy disclosure. In this Policy, "collect" means transmitting data off the device and retaining it in a form accessible to us or to a third party. The App does not do this. Information we receive through TestFlight during the beta (8.6) comes from Apple's beta distribution system and is not collected by the App.

10. International Data Transfers in the App

The data the App stores in the user's own iCloud (the date and time of the first recorded session, and the automatic backup) is not sent to our servers. Storage in iCloud is a service Apple provides to the user, and its handling, including where it is stored, is governed by Apple's Privacy Policy. Processing when the user uses Siri or Apple Intelligence (8.5), and processing in TestFlight (8.6), is likewise a service Apple provides to the user, and its handling is governed by Apple's Privacy Policy. Payment and other processing on the App Store is carried out by Apple as an independent controller on its own responsibility, and such handling is governed by Apple's Privacy Policy.

Part 3 — Common Provisions

11. Operator Information

• Operator: Hideki Mizuta (水田英樹) (sole proprietor; service name "DELT")
• Personal Information Protection Manager: Hideki Mizuta (水田英樹)
• Address: 2F Nishi-Shinjuku Mizuma Bldg, 3-3-13 Nishi-Shinjuku, Shinjuku-ku, Tokyo 160-0023, Japan
• Contact: support@getdelt.com

Requests for disclosure of personal data and similar requests will be handled via the contact above after verification of the requester's identity.

12. Users' Rights

With respect to their own personal data, users may exercise the following rights:

1. Request for disclosure (of personal data and of records of provision to third parties)
2. Request for correction, addition, or deletion
3. Request for suspension of use, erasure, or suspension of provision to third parties
4. Request for notification of the purposes of use

How to make a request: contact us at support@getdelt.com, together with the information necessary to verify your identity. We will, as a rule, respond within 30 days.

12.1 Rights of users in the EU/EEA (GDPR)

Users in the EU/EEA have, in addition to the above, the following rights under Article 15 et seq. of the GDPR: the right to data portability, the right not to be subject to automated decision-making, the right to lodge a complaint with a supervisory authority, and others. Where we act as a controller, the legal bases on which we rely are: the user's consent (for analytics cookies), the performance of a contract (to provide the Site and the App as requested), and our legitimate interests (security and improvement of the Site). As described in Section 10, we do not transfer the date and time of the first recorded session outside the user's country; for purchases, Apple processes data within its own infrastructure as an independent controller within the meaning of Article 13(1)(f) of the GDPR, and we are not the recipient of any such international transfer.

12.2 Rights of users in California, USA (CCPA/CPRA)

Users in California have, under the CCPA/CPRA, rights including the right to know the information collected, the right to delete it, and the right to opt out of its sale or sharing ("Do Not Sell or Share My Personal Information"). We do not sell user information.

13. Security Measures

We take necessary and appropriate measures to prevent the leakage, loss, or damage of user information and to otherwise ensure its secure management. For specifics, please contact us at the address above.

14. Use by Minors

We do not intentionally collect the personal data of children under the age of 16 on the Site or in the App. If we become aware that we have obtained the personal data of a child under 16 without the consent of a parent or guardian, we will promptly delete such information.

15. Revisions to This Policy

We will revise this Policy as necessary. Where we make a material change, we will notify users by an announcement on the Site or by other appropriate means. The revised Policy takes effect from the time it is posted on the Site.

16. Contact

For questions or concerns regarding this Policy or the handling of personal data, please contact:

• Email: support@getdelt.com
• Operator: Hideki Mizuta (水田英樹) (sole proprietor; service name "DELT")