Privacy Policy

1. Who We Are

ZENSUS LTD ("we", "us", "our") is the data controller for personal data collected through the Zensus application ("the App") and website.

Company: ZENSUS LTD Registered address: Office 20089, 182–184 High Street North, East Ham, London, E6 2JA, United Kingdom Privacy contact: support@zensus.co.uk Data Protection Officer: Not yet formally appointed. We monitor this against the GDPR Article 37 threshold as our user base grows. Until a DPO is appointed, direct all privacy enquiries to the address above. EU Representative (GDPR Art. 27): Not yet appointed — in progress. See Section 15 for how to reach us in the meantime.

No separate UK representative is required — ZENSUS LTD is itself the UK establishment.

2. What Personal Data We Collect

2.1 Account & Identity Data

Email address, display name, platform (iOS/Android), language preference, timezone, country code.

2.2 Health & Biometric Data — Special Category Data

Nutrition intake, body measurements, exercise data, sleep ratings, cardiovascular metrics, and demographic data used to calculate targets. This is Special Category data under GDPR Article 9 and is processed on the basis of your explicit consent, given separately from your acceptance of these Terms. The full list of what we collect, why, and how it is protected is set out in our Health Data Agreement — read that document alongside this Policy for complete detail.

2.3 Payment & Financial Data

Subscription and avatar purchase status, payment provider customer ID, transaction history, and refund records. We do not store card numbers, CVV, or full payment details — these are handled directly by our payment processors. See our Subscription Terms and Avatar Purchase Terms.

2.4 Device & Technical Data

Device fingerprint, IP address (encrypted in audit logs), push notification tokens, user agent strings.

2.5 Content Contributions

Translation submissions for health content, votes on health content, user feedback, and Teams messages (see Section 9).

2.6 Authentication Data

OAuth provider links (Google, Apple ID), JWT token records, login events and account activity.

3. Legal Basis for Processing

4. How We Use Your Data

• Nutrition tracking and personalised analysis
• Body measurement and exercise trend tracking
• Subscription and avatar purchase management
• Push notification and email delivery
• Health content delivery and translation
• Security monitoring and fraud detection
• Customer support and legal compliance
• Gamification (achievements, streaks, quiz games)
• Teams matchmaking and leaderboards

We do not use your health data for advertising, profiling for third-party commercial purposes, or any purpose not listed above.

5. Data Retention

Full retention periods for every data category, and exactly what happens on account deletion, are set out in our Data Retention Policy. In summary: your app data (nutrition, exercise, measurements, Teams, avatars) is kept while your account is active and permanently deleted within 30 days of account deletion. Financial and consent records are retained longer where required by law (7 years and indefinitely, respectively) but are anonymised on deletion.

6. International Data Transfers

Our database is hosted in the United States via Supabase (AWS us-east-1). Our application servers run via Fly.io across three regions for performance reasons: the United States (Ashburn, Virginia), South Africa (Johannesburg), and the United Kingdom (London) — each may process your data depending on which region serves your request. Product analytics (PostHog) is hosted in the European Union. The transfer mechanism for each processor and region is set out below.

If the DPF is invalidated, affected US processors automatically fall back to Standard Contractual Clauses.

7. Your Rights as a Data Subject

Lodging a complaint: - UK (our lead supervisory authority): Information Commissioner's Office (ICO) — ico.org.uk, 0303 123 1113 - EU: your local supervisory authority, or our EU representative once appointed (see Section 1) - Nigeria: Nigeria Data Protection Commission (NDPC), under the Nigeria Data Protection Act 2023 (NDPA) — the NDPA superseded the 2019 NDPR framework and its NITDA administration; NDPC is the current regulator - Philippines: National Privacy Commission (NPC) — privacy.gov.ph - California, USA: see Section 13

8. Health Data — Special Category Processing

We process health and biometric data on the basis of your explicit consent (GDPR Art. 9(2)(a)), given during registration via a separate consent screen — distinct from your acceptance of these Terms. Full detail on what is collected, how it is protected, who else can access it, and your rights over it is in our Health Data Agreement, which you are asked to accept before this data is processed.

9. Teams Feature — Group Data Sharing

Teams let groups of premium members share certain physical performance data and compete on leaderboards. Joining a Team requires a separate, explicit consent at the point of joining (Art. 9(2)(a)), and full detail on exactly what is shared is in our Teams Community Guidelines. In summary:

• Other Team members see your body measurements and circumferences, and your maximum running speed, as exact values
• Your cardiovascular metrics (VO2 max, resting heart rate, ApoB), food logs, and exercise sessions are never shared
• Nutrition is shown only as a group-level average — your individual intake is never visible to other members
• Team messages expire after 24 hours (retained longer only if reported for review)
• Leaving a Team immediately stops your data being visible to other members; your consent record is retained as legal proof of consent and withdrawal

10. Focus Group & Weekly Report Emails

Focus group and product feedback emails, and your weekly nutrition report, are sent only with your opt-in consent (Art. 6(1)(a)) and never pre-ticked. Full detail is in our Focus Group Preferences notice. You can withdraw consent at any time via Profile → Notifications, with no effect on your account or app features.

11. Subscriptions and Payment Data

When you subscribe, we collect and process subscription and payment data to manage your account and comply with financial record-keeping obligations. Payment card data is processed directly by our payment processors (Stripe, Flutterwave, Xendit, Apple, Google) — we do not store card numbers, CVV codes, or full payment details. Financial records are retained for 7 years to comply with tax and accounting law, even after account deletion; user-identifying fields are pseudonymised on deletion. For full billing, cancellation, and refund terms, see our Subscription Terms.

12. Avatars and Virtual Goods

Avatar purchases are one-time transactions, delivered instantly to your account. The same payment processors and data-handling rules as Section 11 apply. Full purchase, ownership, and refund terms are in our Avatar Purchase Terms.

During the open beta only, some free avatars are based on the likeness of a real creator — mostly recipe and cooking-video creators (see Section 13). No money is paid to or by anyone for them, and when the open beta ends they are removed from every account. Creators only ever receive aggregate claim numbers — never your name, email, account, or any way to identify you.

13. Sponsorship and Creators

• Sponsorship: as of the effective date of this Policy, no sponsor placements are live in the app. If this changes, we will update this Policy to describe what data, if any, is shared with sponsors before any placement goes live.

13.1 If you apply to become an avatar

The creator programme is open to recipe and cooking-video creators, during the open beta only (plus a small number of other creators we invite directly), and every creator avatar is free. You can apply through our website, in the app, or by emailing support@zensus.co.uk (we recognise creator enquiries among support emails automatically; other support emails are not stored as applications). We collect your name, email address, country, the social media platform and handle you give us, the audience figures you tell us (follower count, average views and average likes and comments per post, other accounts), whether you make recipe content or cooking videos, the cuisines and cooking styles you cook (your food style), the country most of your audience is in, and your message. We use these figures only to decide which applications to take forward, and we check them against your public profile before any agreement. If you apply while logged in, the application is linked to your account.

• Why and legal basis: to assess your application and, if we go ahead, to prepare a contract with you — steps taken at your request before entering into a contract (UK/EU GDPR Art. 6(1)(b)) and our legitimate interest in running the programme (Art. 6(1)(f)). We look at the public social media profile you point us to; we do not buy or scrape data about you from elsewhere.
• Who sees it: Zensus staff only. A daily summary of new applications, including your contact details, is emailed to our support inbox via Mailgun (Section 6).
• How long we keep it: declined or withdrawn applications are deleted 12 months after the last update. If you sign an agreement with us, your application is kept with the agreement (see 13.2).

13.2 If you sign an agreement with us

• Creators: we process your name, likeness, handle, food style, the reference photos or descriptions you give us, and your contact details to produce the avatar, show it in the app with your handle and food style, and run the agreement. If — and only if — you tick the box in your agreement allowing it, we upload your photos to our AI image tool (currently Kling AI, operated by Kuaishou), which stores data in Singapore and may process it in China, and whose terms give it a licence over uploaded content. That transfer relies on your explicit consent (UK/EU GDPR Art. 49(1)(a)), which you can refuse without affecting your application — we then work from descriptions only. Reference photos are deleted within 90 days of your avatar being approved.
• No payments: creators are never paid, so we hold no bank or tax details for you.
• Retention: your avatar, handle and food style are removed from the app — including from every user's account — when the open beta ends or your agreement ends, if sooner. The signed agreement and your application are kept for 6 years after the agreement ends (UK limitation rules).

14. Cookies and Tracking

Our website does not use cookies or third-party trackers. Within the mobile app, we use PostHog (EU-hosted) for product analytics to understand feature usage and improve the service. See Section 6 for processor detail.

15. Data Breach Notification

In the event of a personal data breach that poses a high risk to your rights and freedoms, we will notify you without undue delay. We are required to notify the UK Information Commissioner's Office (ICO) — our lead supervisory authority — within 72 hours of becoming aware of a qualifying breach. Where the breach affects EU residents, we will also notify the relevant EU supervisory authority via our Article 27 representative once appointed. If you believe your data has been compromised, contact support@zensus.co.uk.

16. California Privacy Rights (CCPA/CPRA)

These rights apply once certain revenue/user thresholds are met; they do not currently apply to us. If you are a California resident, you may still contact us with any privacy question and we will respond within 45 days. We do not sell personal information.

17. Children and Young People

Zensus requires users to be at least 16 years old. We do not knowingly collect data from anyone under 16. Users aged 16–17 are permitted to use Zensus; see Section 11 of our Health Data Agreement for the specific protections that apply to this age group.

18. Contact and How to Exercise Your Rights

Privacy contact: support@zensus.co.uk Data Protection Officer: not yet appointed — see Section 1 Response time: within 30 days, as required by GDPR Art. 12

Postal address: ZENSUS LTD Office 20089, 182–184 High Street North East Ham, London, E6 2JA United Kingdom

19. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email and/or an in-app notice. The "Effective date" above reflects the most recent revision. Continued use of the app after changes constitutes acceptance of the updated policy.

This Policy forms part of the Zensus legal framework alongside our Terms of Service, Health Data Agreement, Subscription Terms, Avatar Purchase Terms, Teams Community Guidelines, Focus Group Preferences, and Data Retention Policy. This Policy is governed by the laws of England and Wales. The English version is the legally binding version.