FACTION
Privacy Policy
Effective date: 13 August 2026 · Last updated: 13 August 2026
This Privacy Policy ("Policy") describes how The Faction Group Ltd collects, uses, shares, and protects your personal information when you use FACTION, and how you can exercise your privacy rights. Please read it carefully before using the Services. It should be read alongside our Terms of Service ("Terms"), which govern your use of FACTION.
1. Who We Are
This Policy applies to FACTION's platform, including our mobile applications, the website at factionapp.co.uk, and all related products, software, and services (collectively, the "Services").
In this Policy, "FACTION", “Faction”, "we", "us", and "our" refers to The Faction Group Ltd, a company registered in England and Wales (company number: 17168937).
FACTION acts as the data controller for the personal information we process about you.
FACTION is an 18+ platform. You must be at least 18 years old to create an account or use the Services. See Section 11 for more on our age policy.
For individuals in the United States: please also see Section 15 (Notice for US Residents).
2. The Information We Collect
2.1 Information you provide to us
Account information: when you create an account, we collect your email address and a password, plus a username, a display name, your date of birth, and (optionally) your gender. We use your date of birth to confirm you are 18 or over. Your password is stored securely in hashed form and cannot be read by us or our service providers.
Profile information: You may choose to provide additional profile information, including a bio and an affiliation with a gym. If the gym you train at isn't in our directory, you can propose it, in which case we collect the gym details you provide (gym name, postcode, city, and nation).
Your postcode and derived location: During onboarding, or later in your settings, you may choose to provide your full UK postcode. We store the postcode you enter, and we derive and store from it your town, city, region, and nation. We use this information to place you on local, city, and national leaderboards. Providing a postcode is optional – without it you simply don't appear on rankings above gym level. You can update or clear your postcode at any time in your settings; clearing it removes all of the derived location information as well.
Preferences and settings: We collect and store your account visibility setting (public or private) and other preferences you set in the app.
Group information: If you create a group, we collect the information you provide about it, including the group name, description, and whether it is open or invite-only, along with member invites you send.
Reports and blocks: If you report a group, gym, workout, or user, we collect your report, including the reason you select and any details you write. Reports are visible only to our moderation team – not to the person or thing you reported. If you block another user, we record the block so we can enforce it. Blocking removes any follow connection between you and the blocked user and stops each of you from seeing the other's profile and shared workouts. Neither of you will appear in the other's search results or friend recommendations. Because gyms and groups are shared spaces, a blocked user may still appear alongside you in member lists and leaderboards; where they do, they are labelled to you as blocked. We do not notify a user that they have been blocked, and nothing in their app indicates it.
Support information: When you contact us for support or to make a privacy request, we collect the information you provide in connection with your request, including your email address, the content of your message, and any attachments.
2.2 Information generated through your use of the Services
Activity data: We collect information about the workouts you record on FACTION, including sport type, session name, date, duration, a perceived effort score, calories burned if you choose to enter them, and any notes you add. This may include exercise-specific details such as equipment used, weights, reps, sets, distances, durations, and jump heights, together with server-computed summaries such as total volume and personal bests.
Health-related data you choose to log: For each workout you may optionally record your average and maximum heart rate. You type these in yourself – FACTION does not connect to Apple Health, any wearable, or any other health data source. Because this is health-related information, we treat it as requiring your explicit consent (see Section 5), and you can simply leave these fields blank.
Content you create: We collect and store content you create or share on FACTION, including workout posts and notes, comments, reactions, group chat messages and reactions to them, and users you tag in workouts. For group chat, we also store a per-group marker of the last message you have seen, which powers unread badges.
Interaction data: We collect information about how you interact with other users, including who you follow and who follows you, follow requests you send or receive, and groups you join. In-app notifications (for example, that someone liked your workout) are generated from this activity.
Performance metrics: We generate metrics and visualisations from your activity data to help you analyse your performance, track progress, and compare against other users (subject to your privacy settings).
Live device location: One feature - the "gyms near you" list on the Explore tab - uses your device's location. If you grant location permission, the app takes a single location reading when you open that screen and works out your distance to nearby gyms on your device. Your coordinates are never transmitted to our servers and are never stored against your account. If you decline permission, the feature is simply unavailable; everything else works normally. You can revoke location permission at any time in your device settings.
On-device data that stays on your phone: Some data is stored only on your device and never sent to us: your sign-in session tokens (which keep you logged in) and your recent profile searches on the Explore tab. Uninstalling the app removes them.
Device and technical information: When your device communicates with our servers, standard technical information is processed, such as your IP address and request metadata, in server logs operated by our hosting provider. These logs are retained for approximately 24 hours and are then deleted automatically.
Communications from other users: We may receive information about you from other users of the Services – for example, when they tag you in a workout, comment on your activities, include you in a group, or report your content to our moderation team.
Feedback: We may collect feedback you provide through surveys or questionnaires.
3. Cookies and Tracking
The FACTION app uses token-based authentication rather than cookies, and does not include any third-party analytics or advertising trackers. The website at factionapp.co.uk currently uses no cookies. If this changes, we will update this Policy first.
4. How We Use Your Information
To provide the Services: To create and maintain your account, record and analyse your workouts, run social features including following, comments, reactions, groups, group chat, and leaderboards, help you discover other users, gyms, and groups, and personalise your experience.
To support you: To respond to your support requests and privacy requests.
To maintain and improve the Services: To operate, troubleshoot, and develop the Services.
To send marketing communications: If you opt in, we may send you marketing emails about new features and product updates. You can withdraw consent at any time through the unsubscribe link in any marketing email or by contacting us. We do not currently send marketing push notifications.
To protect users and the Services: To review reports, detect and remove content that violates our Terms, investigate suspicious or harmful behaviour, enforce our Terms, suspend or terminate accounts where necessary, and prevent fraud, abuse, and harm.
To meet legal and regulatory obligations: To respond to lawful requests from authorities, comply with our legal and tax obligations, and manage disputes.
5. Legal Bases for Processing (UK Users)
Under UK data protection law, we must identify a valid legal basis for processing your personal information. We rely on the following:
Creating and maintaining your account; providing the core Services (workout logging including your perceived effort score, social features, groups, chat, and leaderboards) – Contract: processing is necessary to perform our Terms with you.
Health-related data you choose to log (your average and maximum heart rate) – Explicit consent under Article 9(2)(a) UK GDPR. These fields are optional and blank by default. We process them only where you choose to enter them, and you can leave them empty at any time without affecting anything else in the app. To withdraw consent for data you have already recorded, you can edit or delete the workouts containing it, delete your account, or contact us and we will remove it. Withdrawing consent does not undo processing carried out before you withdrew it.
Your postcode and derived location - Legitimate interests: we have a legitimate interest in operating local, city, and national leaderboards, which are a core part of the product. The field is optional and you can clear it at any time.
Live device location – Consent, given through the operating-system permission prompt. Your coordinates are processed on your device only. You can withdraw consent at any time by revoking location permission in your device settings.
Content moderation, reports, and protecting the integrity of the Services - Legitimate interests: we have a legitimate interest in keeping FACTION safe for all users.
Responding to support and privacy requests – Contract and legitimate interests.
Sending marketing emails – Consent, which you can withdraw at any time.
Complying with legal obligations – Legal obligation.
Investigating fraud, abuse, or protecting user safety - Legitimate interests and, where applicable, vital interests.
Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights and freedoms.
6. Who We Share Your Information With
With other FACTION users: Information you share on FACTION – your profile, workouts, posts, comments, and group chat messages – may be visible to other users. If your profile is public, your shared workouts are visible to any signed-in user; if private, only to followers you have accepted. Other users may compare their performance metrics against yours on the same basis.
Groups: A workout only appears in a group's feed, statistics, and leaderboards if you select that group when you log it. Workouts you don't post to a group are not counted towards that group's totals.
Leaderboards and rankings: Leaderboards work differently from the rest of the app. Because a gym's or group's leaderboard is a shared, objective record of that gym or group, your name, display name, and totals appear on it to other members even if your profile is set to private, and to members you have blocked or who have blocked you. Your individual workouts remain protected by your privacy settings – only the ranking entry is shared. If you don't want to appear on a leaderboard, you can remove your gym affiliation or leave the group in your settings.
With our service providers: We work with a small number of trusted third parties to operate the Services. Each is bound by a written contract requiring them to protect your information and only use it to provide services to us:
Supabase, Inc. – our backend provider, hosting your account, activity, and content data. Our database is hosted in Ireland (EU).
Vercel, Inc. – website hosting.
We review our service providers periodically and may change them as our needs evolve. If we add a provider that handles your personal information, we will update this Policy.
With third parties you choose to share with: If you share your content outside FACTION – for example, sending a workout to a friend by text – that information becomes subject to the receiving service's privacy practices.
For legal and safety reasons: We may preserve and share your information with law enforcement, regulatory bodies, or private litigants if we determine in good faith that disclosure is required by law, court order, subpoena, or other legal process; necessary to prevent death, serious harm, or significant threats to safety; necessary to address national security or public interest issues; necessary to investigate or prevent violations of our Terms, fraud, or abuse; or necessary to protect our rights, property, or operations, including in connection with actual or potential litigation.
In connection with a business transaction: If FACTION is involved in a merger, acquisition, financing, reorganisation, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.
7. International Data Transfers
FACTION is based in the UK and our database is hosted in Ireland, within the European Economic Area. The UK recognises the EEA as providing an equivalent level of data protection, so no additional safeguards are required for this transfer. Some of our service providers are US companies and may access or process personal information in the United States. Where we transfer personal information outside the UK to a country without an equivalent level of data protection, we use safeguards approved by the ICO, including the UK International Data Transfer Agreement or the Standard Contractual Clauses with the UK Addendum. For more information contact us at support@factionapp.co.uk.
8. How Long We Keep Your Information
We keep your personal information for as long as your account is active. If you delete your account, your account and its data are deleted immediately and permanently from our live systems – this is a hard delete with no undo. We may retain specific information where required by law, to resolve disputes, or to prevent fraud and abuse. Moderation reports may be retained after account deletion where needed to keep the platform safe. Data stored locally on your device is removed when you uninstall the FACTION app.
9. How We Protect Your Information
We implement technical and organisational measures to protect your personal information, including encryption of data in transit (HTTPS/TLS), hashed password storage, and database-level access rules limiting what each signed-in user can read and write. If we become aware of a data breach likely to result in a risk to your rights, we will notify the ICO within 72 hours. Where the risk is high, we will also notify you directly.
10. Your Rights and Choices
For UK users, your rights include:
Access: You can request a copy of the personal information we hold about you. Much of it is visible directly in the app.
Rectification: You can correct inaccurate or incomplete information, largely through your account settings.
Erasure: You can delete individual workouts and your entire account in the app (Profile → Settings → Delete account). Account deletion is permanent. We cannot control content you have already shared with others outside FACTION.
Restriction: You can ask us to restrict how we use your information in certain circumstances.
Objection: You can object to processing based on legitimate interests.
Portability: You can request a copy of your personal information in a common, machine-readable format.
Withdraw consent: Where we rely on consent, you can withdraw it at any time.
Complain: You can complain to the ICO at ico.org.uk. We would appreciate the chance to address your concerns first.
How to exercise your rights: Use your account settings where possible; for anything else, email support@factionapp.co.uk. We may ask you to verify your identity before acting on a request. We will respond within one month, and will let you know if we need longer for a complex request.
11. Age of Users and Children's Privacy
FACTION is an 18+ platform. You must be at least 18 years old to create an account or use the Services. During signup, we collect your date of birth and the app will not let you proceed if you are under 18.
We do not knowingly collect personal information from anyone under 18. If we become aware that we have collected information from a person under 18, we will delete the account and associated data promptly. If you believe a person under 18 has provided information to FACTION – whether you are their parent or guardian, or anyone else – please contact us at support@factionapp.co.uk and we will take appropriate action.
12. UK Specific Information
Our lead supervisory authority is the UK Information Commissioner's Office (ico.org.uk). Our ICO registration is ZC157864.
FACTION is currently directed at users in the United Kingdom and the United States. If we extend the Services to users in the European Economic Area, we will appoint an EU Representative under Article 27 EU GDPR and update this Policy accordingly.
13. Changes to This Policy
We may update this Policy from time to time, including before we launch new features that change what information we collect. If we make material changes, we will provide prominent advance notice through the Services, by email, or by other appropriate means. We will keep prior versions available on request. If you disagree with any changes, please stop using the Services and delete your account.
14. Contact Us
Email: support@factionapp.co.uk
The Faction Group Ltd
Brynawel, Penuel, Llanmorlais
Swansea, SA4 3UQ
United Kingdom
15. Notice for US Residents
This Section applies to residents of US states with comprehensive privacy laws, including California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia, and Washington, as well as any other state that enacts similar laws.
Categories of personal information we collect:
Identifiers – email address, username, user ID, and IP address processed by our hosting provider
Personal information described in Cal. Civ. Code § 1798.80(e) – name or display name, and email address
Internet or network activity information – technical request information processed by our hosting provider
Geolocation information – the postcode and derived town/city/region/nation you choose to provide; precise device location is processed on your device only and is not collected by us
Health and fitness information – workout data, including effort scores, and, if you choose to log it, your average and maximum heart rate
Inferences drawn from the above – performance metrics
User content – posts, comments, chat messages, and reports
Our Services are restricted to users 18 and over. We do not sell personal information and we do not use it for targeted advertising.
Your rights under US State Privacy Laws: Depending on your state of residence, you may have the right to know or access the personal information we collect about you; to delete it; to correct it; to receive it in a portable format; to opt out of profiling that produces legal or similarly significant effects (we do not engage in such profiling); to limit the use of sensitive personal information (we do not use sensitive personal information beyond what is necessary to provide the Services); to non-discrimination for exercising your rights; and to appeal a decision we make about your request. To exercise your rights, email support@factionapp.co.uk. We will verify your identity and respond within the timeframes required by applicable law. If we decline your request, you can appeal by replying to our response.
Authorised agents: You may designate an authorised agent to exercise your rights on your behalf. We may require verification of the agent's authority and your identity.
Washington My Health My Data Act. For residents of Washington State: some of the information we collect (including workout data, effort scores and, where you log it, heart rate) constitutes "consumer health data" under the MHMDA. Heart rate fields are optional and blank by default and we collect heart rate only where you choose to enter it; workout data and effort scores are collected when you choose to log a workout. We do not share consumer health data except with the service providers necessary to operate the Services. You can withdraw consent, access, and delete consumer health data at any time through the app or by contacting us.
Notice at collection (California): The categories listed above are collected for the purposes set out in Section 4 and retained for the periods described in Section 8.
End of Policy