Privacy Policy
Safeguarding Your Data: Centenum Health Dedication to Privacy and Security
Data that helps to serve you When you use Centenum Health, we collect your personal data and often sensitive data such as health and Diet data. We use it to improve your experience and service. We can then increase the safety and accuracy of your predictions and give you relevant app content and product offers.
You can contribute to the growth of the Centenum Health community If you consent, we may use technical information about your device and other information about you (such as your device's unique technical identifier, age group, subscription status, emails and the fact you launch the app) to reach you for promotional purposes.
You're in control and can reach out to us We believe in transparent and open conversation - you can access, modify, correct, erase, and update your personal data by emailing us at thecentenum@gmail.com or emailing our data protection officer at legal@centenum.com Where we rely on your consent to process your personal data, you can withdraw your consent. If you have any questions about this Privacy Policy, let us know.
We limit children's access to the app You must be at least 18 years old to use the app. This is the legal requirement for users in Nigeria.
Introduction This Privacy Policy explains how Centenum Health and its affiliated entities (“DietBloom” or “we” or “us”) complies with the provisions of the Nigeria Data Protection Act (“NDPA”), the Nigeria NDPA and any other applicable data protection laws and regulations. This Privacy Policy explains how Centenum Health collects, stores, uses, transfers, and shares personal data from our users (“you”) in connection with the Centenum Health mobile application.
Centenum Health is a Nigeria registered data controller of the Services.
We may change this Privacy Policy from time to time. If the changes are material, we will notify you by email or through the App. If permitted by law, your continued use of the Services after this policy has been updated indicates your acceptance of changes made. In some cases, you will be given a choice to accept changes to this policy. If you
The latest updates to this policy are available on our Website and in the App.
Personal data we collect from you We collect personal data about you when you interact with the Services. This can be directly from you or from other sources and third parties.
- Personal data you provide to us directly:
General information: When you sign up to use the Services, we may collect personal data such as your name, email address, year and month of birth, password, place of residence and location information including time zone and language. We may be able to infer your sex and/or gender by your use of the Services.
You may also choose to input information such as your first name or the name you would like us to call you. This is led by you and it will not affect your use of the Services should you choose not to enter this information.
When using the Services, you can choose to input personal data about yourself to support your dietary and wellness goals. This may include details such as your weight, height, body mass index (BMI), daily calorie intake, food preferences, and dietary restrictions. You may also input information related to your hydration levels, sleep duration, physical activity, mood, and general well-being. Additionally, you can log details on specific health goals, like weight management or nutrient tracking, as well as any symptoms or conditions that may impact your dietary habits and health journey.
Third-party Services (including Wearables): With your consent, you may choose to connect Centenum Health to third-party services, such as Apple HealthKit and Google Health Connect, allowing us to seamlessly import health and activity data directly into the app. This imported data may include information on fitness activities, weight, height, BMI, calories burned, heart rate, steps taken, sleep duration, and other relevant health metrics. By integrating this data, we aim to provide you with more personalized insights into your dietary habits and overall wellness, helping us make more accurate dietary recommendations and progress assessments. Please note that the import and use of this data are subject to Google Health Connect and Apple HealthKit privacy policies and terms. Additionally, please review the terms and privacy policies of any wearable devices you connect to Centenum Health, as these providers may collect usage data related to your connection for their own service improvements.
- Personal data we collect automatically:
When you access or use the Services, we may automatically collect the following information:
Device information: device model; information about the operating system and its version; unique device identifiers; enabled device accessibility features (e.g., display features, hearing features, and physical and motor features); mobile operator and network information; device storage information or version of your device system.
Location information: IP address for an approximate location (not precise location); time zone or information about your mobile service provider.
Data about your use of the Services, including: frequency of use; areas and features of the Services that you access or use; payment transaction information (excluding full payment card details) or engagement with particular features.
To collect this and other information, we may use cookies and other similar technologies.
Data from external sources: we may receive personal data about you from third parties. For example, we may obtain information from third parties to enhance or supplement your existing information, including to customize your experience and for statistical purposes and analytics.
How we use your personal data Depending on which features of the Services you use, we will process your personal data based on one or more of the following legal bases (we have included some examples):
- Your consent: you can give us permission to process your health data to provide the Services.
- To fulfill our contractual obligations to you in order to provide the Services to you: we may process your personal data to fulfill our contractual obligation to you for activities such as management of your Centenum Health account and other administrative purposes.
- Legitimate interest: we may process your personal data based on our legitimate interests in order to manage our Services better. For example, we may use your personal data in order to:
- identify and fix bugs;
- determine genuine user interaction with the Services (rather than bots);
- monitor the App and analyze its performance and reliability;
- inform you of matters concerning your subscriptions;
- conduct vulnerability scanning to protect the security of the Services; and
- review aggregated App usage trends.
Further examples of our legitimate interests are outlined in the table below. When relying on this legal basis, we first determine that we have a legitimate interest in conducting and managing our business. We then consider and balance potential impacts to you and your rights, to ensure that our interests do not override them. - Legal obligation: We may be obligated to process some of your personal data to comply with applicable laws and regulations.
Below, we describe the purposes for which we process your personal data and our lawful bases for doing so, including some basic examples:
Principles of processing
Data minimization and purpose limitation: We will not process personal data in a way that is incompatible with the purposes for which it has been collected or authorized by you or collect any personal data that is not needed for the mentioned purposes.
No sale of personal data: We will not sell or rent your personal data for monetary gain. We will not disclose your personal data except as otherwise described in this Privacy Policy. We will share your personal data with our service providers who support our Services as described in this Privacy Policy. We will also not use information received through your use of the Apple HealthKit or Google Health Connect framework for advertising or similar services, or sell it to advertising platforms, data brokers, or information resellers.
Your privacy rights It does not matter what country, state, or region you come from; we are committed to providing you with individual privacy rights in accordance with the NDPA in relation to your personal data.
What are these rights?
Only you or a person legally authorized to act on your behalf may make a verifiable request related to your personal data. We reserve the right to perform reasonable checks to confirm a person's authorization, (for example, in the US, we may check if they are a person registered with the California Secretary of State).
Correction of your personal data If you believe that your personal data is inaccurate, you have the right to contact us and ask us to correct such personal data.
Restriction of processing You have the right to request that the processing of your personal data be restricted in some circumstances. For example, you have the right to request the restriction of your personal data if you contest the accuracy of your personal data and we need some time to verify such accuracy.
Access to your personal data You have the right to request information about what personal data we process about you, to access all your personal data and to receive a copy of it, including in a structured and portable form (.json). For iOS Centenum Health Premium users, the App also enables you to download a report containing some of your personal data from within the App.
Right to data portability You have the right to request your personal data in a portable form which enables you to, for instance, reuse your data for your individual purposes or different services. In other words, it may allow you to move, copy or transfer personal data from Centenum Health in a safe and secure way.
Erasure of your personal data You have the right to request that we erase your personal data at any time. Please be aware that erasing some personal data may affect your experience using certain features of the Services that rely on historical data.
Objection to the processing of your personal data You have the right to object to the processing of your personal data, for example, if we process it for direct marketing purposes.
How to exercise your privacy rights
Please email us at thecentenum@gmail.com or legal@centenum.com to exercise your privacy rights.
If you would like to exercise your right to request erasure of your account, you can visit the settings in your App.
We will address your request within 7 working days after receipt. It can take us up to 21 days in some cases, for example, for full erasure of your personal data stored in our backup systems. We will let you know if we need more time and explain the reasons for the delay.
We rely on your consent to process your health data to access the Services. You can withdraw this consent by contacting us or deleting your account in the App.
What else?
Please keep in mind that if we receive a vague request, we may contact you to better understand the request. We may also refuse to comply with or charge a reasonable fee for a request that is manifestly unfounded and/or excessive (repetitive) requests.
We will require you to prove your identity. Normally, we will verify that the request is coming from the same email that you provided when registering. If you have not registered your account, we may ask you to undergo additional verification checks to ensure we can appropriately respond to you.
Subject to applicable laws, you may have the right to lodge a complaint with your local data protection authority about any of our activities. If you have any concerns about our privacy practices, please let us know by emailing our support team at thecentenum@gmail.com or by emailing our data protection officer at legal@centenum.com
Third parties processing your personal data We will not share your personal data with third parties except as specified within this Privacy Policy.
Promoting our Services With your consent, we may share some of your non-health personal data with Apps to promote the Services.
Processing to make the App run In some situations, we engage other companies to process your personal data on our behalf. We refer to these companies or service providers as “processors.”
Processors are companies that help us run the Services, support our communication with you, or perform other App-related activities. They process certain personal data on our behalf to accomplish the goals related to the App functions and deliver the Services. We remain responsible for any acts or omissions of our processors, and we enter into data processing contracts with them to the extent required by applicable law.
Aggregated information We may aggregate, anonymize, or de-identify your personal data so that it cannot reasonably be used to identify you. We may share such data with third parties such as academic research institutions or use the data for statistical purposes. For example, we may share or use general age and demographic information and aggregate statistics about certain activities or symptoms from data collected to help identify patterns across users in articles, blog posts, and scientific publications. Sharing such data may contribute to the advancement of scientific research on female health.
For certain targeted academic or user research studies, we will contact you and rely on your consent. You can withdraw your consent at any time by emailing us at legal@centenum.com
We may also preserve or share some of your personal data in the following limited circumstances: - in response to subpoenas, court orders, or legal processes, to the extent permitted and as required by applicable law (including to meet national security or law enforcement requirements);
- when disclosure is required to maintain the security and integrity of the Services or to protect any user's security or the security of other persons, consistent with applicable laws. In such cases, we may also delete some of your personal data (e.g., by resetting your password to avoid unauthorized access);;
- to assert legal rights or defend against legal claims;
- when disclosure is directed or consented to by the user who has inputted the personal data;
- in the context of an acquisition or transfer of any party of our business or in connection with the business reorganization; and
- depending on the circumstance, we may rely on legitimate interest or legal obligation as our legal basis for the processing activities above.
Retention of your personal data Except as set forth below, we will retain your personal data for as long as needed to provide you with the Services or otherwise fulfill the purposes for which it was collected.
Impact of account deactivation/requests to erase personal data: At any time, you can deactivate your account by following the steps detailed above at 'How to exercise your privacy rights'. We will address your deletion request within one-month after receipt. It will take us up to 90 days in some cases to complete full erasure of your personal data stored in our backup systems. If you choose to deactivate your account, Centenum Health will generally delete all your personal data, and it will not be recoverable should you later create another account.
Impact of App deletion or inactivity: If you choose to delete the App from your device or your account becomes inactive, we will retain your personal data for a period of three months in case you decide to reactivate the Services or reinstall the App. After three months of inactivity, we will delete your personal information. While this is the
Centenum Health data retention standard, you can still ask for your data to be deleted at an earlier date by contacting us. The App covers different periods of users' lifecycle; therefore, retention of your data is needed in some cases to secure your smooth experience with other App functions (e.g., switching to pregnancy mode after cycle tracking).
Limitations: You should be aware that although we will delete, anonymize or otherwise de-identify your data where possible, we may retain certain personal data and other information after your account has been terminated or deleted. This is as required and permitted by applicable law, like the NDPA, and will include the following circumstances:
- as necessary to comply with legal obligations;
- establishment, exercise or defense of legal claims; and
- for archiving purposes in the public interest, scientific or historical research or statistical purposes.
How do we delete your data? We use industry-standard methods and procedures to ensure that we securely and permanently delete your personal data from our systems so that it is no longer capable of recovery. These procedures can include automated notifications to some of our processors who process your personal data on our behalf.
Security of your personal data
General security measures We implement technical and organizational measures in an effort to protect personal data from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the nature of the personal data that we process and risks associated with special categories of personal data we collect. This includes:
- Encryption of your personal data in transit and in rest;
- Systematic vulnerability scanning and penetration testing;
- Protection of data integrity;
- organizational and legal measures: For example, our employees have different levels of access to your personal data and only access your personal data for limited and necessary purposes required for the operation of the Services. We impose strict responsibility on our employees for any disclosure, unauthorized access, alteration, destruction, or misuse of your personal data; and
- Conducting periodical Data Protection Impact Assessments (DPIA) in order to ensure that the Services fully adhere to the principles of privacy by design, privacy by default, and others. We also commit to undertake a privacy audit in the event of Centenum Health's merger or takeover.
Please protect your password. Do not share it with others or allow anyone to use your mobile device. You may also wish to add a passcode or enable face ID to access the App for an added layer of protection.
No security system is perfect. Therefore, we cannot guarantee the absolute security of the Services or that your information will not be intercepted while being transmitted to us.
Security breaches If we learn of a security systems breach, we may either post a notice or attempt to notify you by email and will take reasonable steps to remedy the breach as specified in applicable law and this Privacy Policy. If we learn of a potential personal data breach, together with other actions referred to in the Privacy Policy, we will take actions to remedy the breach as appropriate under the circumstances, which may include logging you out from all the devices, resetting a password (sending a temporary password for you to apply), and performing other reasonably necessary activities.
If you want to report a security incident related to the Services, please email us at legal@centenum.com
Children's privacy General age limitation: The Services are not intended for children, and we do not knowingly collect personal information from children under 18 years old through the Services. If you are aware of anyone under 18 years old using the Services, please email us at thecentenum@gmail.com and we will take the required steps to delete such information and/or delete the child's account.
Communication with you We may contact you from time to time via email or through other means (like pop-ups or push notifications) to communicate with you about Services, offers, promotions, rewards, and events offered by us and provide news and information that we think will be of interest to you. These communications may be based on the Services you have selected for use (e.g. your selected mode) and the App features you engage with.
Opt-out options: You can always opt out of receiving marketing emails by unsubscribing via the “Unsubscribe” link contained in the email. Opting out of these marketing emails or notifications will not end the transmission of service-related emails that are necessary to your use of the Services. You may also opt out of receiving push notifications by adjusting your settings in your device. If required, we may ask some users to provide additional consent for such communications.
Please note that we may contact you with information about Services, offers, promotions, rewards, and events offered by us and others via third-party platforms (like social media).
Presence on social networks We may use social media platforms to promote Centenum Health and engage with our customers. When you interact with us on these platforms, we may process information, such as your username, profile picture, and any comments or posts you make related to Centenum Health, for engagement purposes only.
Storage and international personal data transfers Centenum Health is based in Nigeria. Personal data we collect is transferred to and processed in Nigeria; where it is governed by Nigeria law) and to other countries (where it is governed by the applicable laws of those countries). These transfers are usually cloud-based, and can occur when you engage with the Services and are subject to our retention policies. The laws of other countries may not offer the same protections as the laws of your jurisdiction.
Transfers of personal data outside Nigeria Personal data in Nigeria is protected by the NDPA. When transferring personal data outside of this location, we will always apply appropriate safeguards in accordance with the law to ensure your personal data is protected.
References to “personal data” in this policy include “sensitive/personal information” as defined under Nigeria Data Protection Act.
Contact us If you have any questions or concerns about your privacy, you may contact us or our data protection officer by writing to us at: thecentenum@gmail.com or legal@centenum.com
