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 (customer portal) and Mobile Companion App (together, 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

Centrum Jonas s.r.o., 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 and 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 and non-fertile days, ovulation, calculated indicators)

c) Mobile App - Identification data: name, email - Calendar data: fertile and non-fertile days, ovulation, calculated indicators - User entries: menstruation dates, sexual activity records, notes - Optional pregnancy records: outcome (childbirth or miscarriage), date, time and place, the child's gender, weight and length - Messages exchanged with our support team The Mobile App displays and records a subset of the data held in the Web App. This data includes reproductive health data.

d) Statistical evaluation Your calendar records (menstruation dates, intercourse records) and a summary of your pregnancies (for example: number of pregnancies and the outcome of each) are evaluated to verify the calculation. The evaluation is also provided to you. For statistical purposes only year of birth, country and this summary are used, in anonymised form. Detailed pregnancy records (date, place, weight and length) are used only to provide your calculation. We publish results only in aggregated form.

5. Purposes of Processing

- Account creation and authentication

- Provision of the calculation and the personalised calendar

- Access to Mobile App features

- Evaluation of the calculation and statistical evaluation of the Jonas Method

- System improvement - Compliance with legal obligations The Services display calculations of the Jonas Method based on user-provided data. They are provided for informational purposes only and do not constitute medical advice, diagnosis or treatment. No result can be guaranteed.

6. Legal Basis

- Art. 6(1)(b) GDPR – performance of a contract

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

- Art. 9(2)(a) GDPR – explicit consent, given at registration, for the processing of reproductive and health-related data for providing the calculation, evaluating it and for the statistical evaluation described in section 4d

7. Notifications in the Mobile App

Notifications are optional, switched off by default and scheduled locally on your device. 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 service providers (e.g. hosting and IT providers) acting as processors under GDPR-compliant agreements. Access is restricted to authorised personnel. We do not sell personal data. 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, to ensure continuity of calculations for users planning future pregnancies, for up to 10 years afterwards, unless a longer period is required by law. You can request deletion of your account and personal data at any time in the customer portal (Web App) under account management, or by e-mail at support@centrumjonas.com. [If you request deletion, your data is erased without undue delay, except where we are legally required to retain it.] After deletion, access to the Services, including the personalised calendar, is no longer available. Deletion is irreversible.

10. Data Security

- Encryption in transit and at rest

- Access control and authentication

- Hosting within the European Union

- Regular security monitoring

11. International Transfers

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

12. Your Rights

Under GDPR you have the right to access, rectify, erase, restrict, object to processing and data portability, and to withdraw consent at any time. Withdrawal does not affect the lawfulness of earlier processing. Because the calculation cannot be provided without the data, withdrawal of consent means deletion of your account. You may lodge a complaint with a supervisory authority (in Slovakia: Úrad na ochranu osobných údajov SR).

13. Provision of Data

Certain personal and health-related data are necessary for the Services. Without them, the calculation and calendar cannot be provided.

14. Cookies

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

15. Changes to this Policy

We may update this Policy. Significant changes will be communicated via the Services or e-mail.

16. 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, including its evaluation and statistical use as described in section 4d - Acknowledge their rights under GDPR Consent is given by a clear affirmative action during registration.

Bratislava, 2025