Privacy Policy

1. Introduction

Centenary Day ("Centenary Day", "we", "us", or "our") values your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our mobile application, APIs, or any related Services (collectively, the "Platform").

2. Scope

This Policy applies to all users of the Platform and to all personal data processed by Centenary Day, including data that can directly or indirectly identify you ("Personal Data"). It is designed to comply with the European Union General Data Protection Regulation (GDPR) and other applicable privacy laws.

3. Data We Collect

3.1 Information You Provide

• Account Data: name, email address, password, age, gender, preferred language.
• Health & Biomarker Data: blood test results, genetic data, fitness metrics, nutrition logs, sleep data, and any other information you choose to upload or input into the Platform.
• Payment Data: billing address, payment method details (processed by our payment processors).
• Communications: messages, feedback, support inquiries, survey responses.

3.2 Information We Collect Automatically

• Usage Data: features you use, actions you take, frequency and duration of sessions.
• Device Data: IP address, operating system, browser type, device identifiers, referral URLs.
• Cookies & Similar Technologies: cookies, local storage, pixels, and SDKs to recognize you and/or your devices.

4. How We Use Your Data

We process your Personal Data for the following purposes:

• To Provide and Improve the Platform: create and manage accounts, deliver features (routine builder, nutrition planner, biomarker dashboard), and develop new tools.
• Personalization: generate tailored longevity recommendations, adaptive routines, and content relevant to your goals.
• Analytics: monitor usage, measure performance, and enhance user experience.
• Communications: send transactional emails, service announcements, reminders, and respond to inquiries.
• Payments: process subscription fees via secure third‑party processors.
• Security & Integrity: detect, prevent, and address technical issues, fraud, and abuse.
• Legal Compliance: comply with applicable laws, regulations, and legal processes.
• Marketing (with consent): send newsletters or promotional materials. You may opt out at any time.

5. Legal Bases for Processing (GDPR)

We rely on the following legal bases:

• Contractual Necessity: to provide the Platform and fulfill our Terms and Conditions.
• Legitimate Interests: to improve services, ensure security, and conduct analytics (without overriding your rights).
• Consent: for processing special category data (health, genetic), sending marketing communications, and setting non‑essential cookies.
• Legal Obligation: to meet tax, accounting, and other regulatory requirements.

6. Sharing & Disclosure

We do not sell your Personal Data. We share data in limited circumstances:

• Service Providers: hosting, analytics, customer support, payment processing, lab integrations—bound by confidentiality obligations.
• Healthcare Professionals (at your direction): if you choose to share reports or grant access via the Platform.
• Legal & Safety: to comply with lawful requests or protect the rights, property, and safety of Centenary Day, users, or the public.
• Business Transfers: in connection with a merger, acquisition, or asset sale. We will notify you of such changes.

7. International Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA) that may not provide the same level of data protection. In such cases, we implement appropriate safeguards, including Standard Contractual Clauses approved by the European Commission.

8. Data Retention

We retain Personal Data for as long as your account is active or as needed to provide the Platform and fulfill the purposes outlined in this Policy. We may also retain certain information as required by law or for legitimate business purposes, such as dispute resolution and enforcement of agreements.

9. Your Rights

Subject to applicable law, you have the right to:

• Access, correct, or delete your Personal Data.
• Object to or restrict our processing.
• Withdraw consent at any time when processing is based on consent.
• Receive a portable copy of your data (data portability).
• Lodge a complaint with a supervisory authority.

To exercise your rights, please contact us using the details in Section 13.

10. Security Measures

We implement technical and organizational measures to protect Personal Data, including encryption in transit and at rest, role‑based access controls, periodic security audits, and incident response procedures. No method of transmission or storage is 100% secure; therefore, we cannot guarantee absolute security.

11. Children's Privacy

The Platform is not directed to children under 16. We do not knowingly collect Personal Data from children. If you believe a child has provided us with Personal Data, please contact us and we will delete the information.

12. Third‑Party Links & Services

The Platform may contain links to third‑party websites or services not operated by Centenary Day. We are not responsible for their privacy practices. We encourage you to review the privacy policies of every third‑party site you visit.

13. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of significant changes by posting the new Policy on this page and updating the "Last updated" date. Continued use of the Platform constitutes acceptance of the revised Policy.

14. Contact Us

If you have questions about this Privacy Policy or our privacy practices, you may contact us at [email protected].

Last updated: 22 May 2025