CONSENT TO THE PROCESSING OF PERSONAL DATA

Privacy Policy – Jonas method Ecosystem (Web, Web App, Mobile App)

1. Introduction
   This Privacy Policy explains how Centrum Jonas s.r.o. (“we”, “our”, “us”) collects, processes, and protects your personal data, including data relating to reproductive health, across our Website, Web App, and Mobile Companion App (collectively, the “Services”).

The Services are intended for registered users who create an account and request a calculation. Certain features require the processing of data related to reproductive health.

2. Data Controller
   Operator: Centrum Jonas s.r.o.
   Address: Tolstého 5, 811 06 Bratislava, Slovakia
   ID: 47 555 700
   Contact: support@centrumjonas.com

3. Minimum Age
   The Services are intended for users aged 18 and over.

4. Categories of Data Collected

a) Website

• Name, email

• Contact form messages

• Technical data (cookies, session data)

b) Web App

• Identification data: name, email

• Birth-related data: date, time, place of birth

• Location of use (city, country)

• Reproductive and health-related data: menstrual cycle, pregnancy-related data, notes (e.g. illness, medication)

• Child-related data: gender, weight, length, viability

• Generated data: fertility calendar (fertile/non-fertile days, ovulation, calculated indicators)

c) Mobile App

• Identification data: name, email

• Limited calendar data: fertile/non-fertile days, ovulation, predicted outcomes

• User entries: menstruation dates, sexual activity records, notes, optional pregnancy updates

Note: The Mobile App displays only a subset of data; however, underlying processing may involve reproductive health data.

d) Statistical Data
With your separate consent (see section 6), pseudonymised calendar records may be used for statistical evaluation. We may process aggregated and anonymized data for analytical purposes and system improvement statistics.

5. Purpose of Processing

Personal data are processed for the following purposes:

• Account creation and user authentication

• Provision of calculation and personalized calendar

• Access to Mobile App features

• System improvement 

• Scientific and statistical evaluation of the Jonas Method (based on separate consent)

• Compliance with legal obligations

The Services provide fertility and cycle-related predictions based on user-provided data and a proprietary calculation model. These predictions are for informational purposes only and do not constitute medical advice.

6. Legal Basis

Processing is based on:

• Article 6(1)(b) GDPR – performance of a contract

• Art. 6(1)(c) GDPR – compliance with legal obligations

• Article 6(1)(a) GDPR – user consent (where applicable)

• Article 9(2)(a) GDPR – explicit consent for processing of special categories of personal data (reproductive and health-related data)

• Art. 6(1)(a) and 9(2)(a) GDPR – separate explicit consent for scientific and statistical evaluation. This consent is optional, is not a condition for using the Services, and can be withdrawn at any time. Results are published only in aggregated form.

7. Notifications in the Mobile App

 Notifications are optional. We do not use push notification tokens and no notification content is sent to or stored on our servers. 

8. Data Recipients and Use Restrictions 

Personal data may be processed by trusted service providers (e.g. hosting or IT providers) acting as data processors under contractual agreements compliant with GDPR.

Access to data is restricted to authorized personnel only.

We do not sell or use personal data for marketing purposes.  Health and reproductive data are never used for advertising or marketing, and are never shared with data brokers. 

9. Data Retention and Deletion 

 Personal and health-related data are retained for the duration of the user relationship and up to 10 years thereafter to ensure the continuity of calculations for users planning future pregnancies, unless a longer retention period is required by law.  

Users have the right to request deletion of their account and personal data at any time in Web App by managing your account. Upon deletion, access to the Services, including the personalized calendar and related features, will no longer be available. The deletion of data is irreversible and may result in the permanent loss of all stored information.

10. Data Security

• Encryption in transit and at rest

• Access control and authentication mechanisms

• Hosting within the European Union

• Regular security monitoring

International Transfers 

Your data is stored and processed within the European Union and is not transferred outside the EEA. 

11. User Rights

Under GDPR, users have the right to:

• Access their data

• Rectify inaccurate data

• Request erasure (“right to be forgotten”)

• Restrict processing

• Object to processing

• Data portability

• Withdraw consent at any time

Withdrawal of consent does not affect the lawfulness of prior processing.

Users also have the right to lodge a complaint with a supervisory authority.

12. Provision of Data

Providing certain personal and health-related data is necessary for the functionality of the Services. Without such data, the calculation and calendar features cannot be provided.

13. Cookies

We use necessary technical cookies required for the operation of the Services (e.g. login, sessions, functionality). No marketing cookies are used.

14. Changes to this Policy

We may update this Privacy Policy from time to time. Users will be informed of significant changes via the Services or email.

15. Consent

By creating an account, users confirm that they:

• Have read and understood this Privacy Policy

• Provide explicit consent to the processing of reproductive and health-related data

• Acknowledge their rights under GDPR

Explicit consent is obtained through a clear affirmative action  during registration.

Bratislava, 2025