Consent to processing of special categories of personal data

Document version: 2026-08-26

This consent is given under Articles 9 and 10 of Russian Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" and is confirmed in the Wolkup mobile app by a separate action, independently of accepting the Terms of Use and the Privacy Policy.

1. Operator

Artem Zaborskikh, private individual, citizen of the Republic of Kazakhstan. Contact email: [email protected]

2. Data subject

The user of the Wolkup mobile app who confirmed this consent in the app under their own account.

height;
body weight and its day-by-day history;
heart rate during workouts: average, maximum and the series of readings for a workout. It comes from your watch during the session, or together with a workout imported from a connected service (Apple Health, Strava).

The data comes from you directly or from services you connect, and qualifies as a special category of personal data as information describing your state of health.

Resting heart rate is not stored on the operator's servers: it stays on your device and is never transmitted to the operator.

4. Purpose of processing

Calculating and displaying personal training metrics: energy expenditure, stride length and distance covered, heart-rate zones, body-weight dynamics, and calibrating training-plan volume.

5. Operations performed on the data

Collection, recording, systematisation, accumulation, storage, updating, retrieval, use, anonymisation, blocking, deletion, destruction.

Processing is automated, with transmission over the Internet. The data is stored on a server located in the Russian Federation. No cross-border transfer of this data takes place. This data is not shared with third parties and is not disclosed to an indefinite range of persons.

From your height and body mass the operator derives coarse aggregate categories (for example, "body load: average") used when generating a training plan, and those categories may be passed to a service provider outside the Russian Federation. The height, body mass and heart rate values themselves are never transmitted, and the original numbers cannot be reconstructed from such a category. See the Personal Data Processing Policy for details.

One exception is the activity feed: if you have workout publishing enabled, a workout's average and maximum heart rate is visible to your followers and friends in the app alongside the workout itself. Publishing can be turned off in your profile; the series of readings never goes to the feed.

6. Validity and withdrawal

The consent is valid until withdrawn.

You may withdraw it at any time in the app: Settings → Health data consent → Withdraw consent, or by writing to [email protected].

Upon withdrawal the operator stops processing this data immediately and erases it 7 days after the withdrawal: height and weight are removed from the profile, the weight history is deleted in full, and heart rate (average, maximum and the series of readings) is erased from all your workouts, imported ones included, and from activity feed entries. The delay exists in case of an accidental withdrawal: if you confirm consent again within those 7 days, the erase is cancelled and nothing is lost. The rest of the app keeps working: withdrawing consent does not delete your account and does not stop workout tracking.

7. Method of confirmation

The consent is confirmed in the Wolkup mobile app by a simple electronic signature — signing in to the account with a one-time code sent to the user's email address. Under the "Simple electronic signature" section of the Terms of Use, the parties treat such confirmation as equivalent to a paper document signed by hand.

The operator records the fact of confirmation: the account, the date and time, and the version of this document.