Cenith Innovations Privacy Policy
Last Updated: April 27, 2023
ABOUT THIS PRIVACY POLICY
At Cenith Innovations, we take the protection of your personal data seriously. This Privacy Policy applies to processing of personal data by Cenith Innovations software products and solutions. (collectively, “Cenith Innovations”).
Our products, like the Cenith Innovations’ Elite Flight, enable you to integrate your own biometric wearable devices, potentially allowing access to your personal health information. We understand that data does not get much more personal than this, and the protection of your personal data is of paramount importance to us. Please take a moment to carefully review this Policy.
WHY DOES Cenith Innovations PROCESS YOUR PERSONAL DATA?
The sections below explain the categories of personal data we collect and process, as well as the reasons we do so, such as to provide you with services within our applications. You will also find information on our legal basis for processing your data, and our data sources.
DEVICE & APPLICATION USERS
PROCESSING PURPOSES
Cenith Innovations collects and processes the personal data of Device & Application Users (“Users”) for the following purposes:
To provide Cenith Innovations services
We process personal data to provide Cenith Innovations services and app features, such as to provide you with insights driven from your health information to allow you to optimize your performance.
To provide customer service
We process personal data for the purpose of providing customer service and managing our customer communication. If you contact our Support with questions regarding your app data, we may use the provided information to answer your questions and for solving any issues you may have.
To develop our products and services
We process data regarding your use of Cenith Innovations applications to improve our services and features, such as in the Cenith Innovations Elite Flight App. When feasible, we will do this using only pseudonymized, aggregated, or non-personally identifiable data.
To market our products and services
We process marketing-related data to provide online advertising and Cenith Innovations marketing communications. For example, as explained more fully in our Cookie Policy, we use cookies on our website in order to create targeted audiences for online advertisement. You can always opt out of marketing communications, and we will only send you our newsletter if you have requested it.
To enable third party integrations and services
We process data you provide to Cenith Innovations to enable third party integrations, services, features, and offerings. Examples of third parties we partner with include research partners, Google Fit, or Apple Health. Cenith Innovations takes measures to help ensure third party services protect your personal data, which means receipt and transmission of your data to and from third party services is undertaken when you have provided Cenith Innovations with the necessary consents.
To comply with legal obligations
In certain cases, we must process certain data when it is required by applicable laws and regulations. Such statutory obligations are related, for example, to accounting and tax requirements, legal claims, or other legal purposes. Cenith Innovations will oppose any request to provide legal authorities with access to user data for surveillance or prosecution purposes, and will notify users if we receive any such request.
LEGAL BASIS FOR PROCESSING
Data protection law in Europe requires a “lawful basis” for collecting and retaining personal information from residents of the European Economic Area. Our lawful bases for processing your data depend on the particular processing purposes, including:
Contract
When processing personal data for the purpose of providing Cenith Innovations services we process it on the basis of a user contract, which is formed when you create your account and accept our terms and conditions.
Consent
We process your health-related data only with your consent. In some cases, you can provide your consent to us for processing your data through your actions, such as by inserting health data into your notes, or by adding health related tags in Cenith Innovations applications.
Legitimate Interest
We process your personal data based on our legitimate interests when we process it for the purposes of marketing our products and services, providing our customer service and improving our products and services. When choosing to use your data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy, in compliance with applicable law.
Legal obligation
Cenith Innovations must process certain information to comply with statutory obligations which may vary in each country. For example, such obligations can relate to consumer protection or tax laws.
PROCESSED DATA AND DATA SOURCE
In most cases, Cenith Innovations collects personal data directly from you, such as when you register for an account, tag your data within Cenith Innovations applications. We may also process data that is produced from the information you provide to us. Cenith Innovations may also rely on trusted third party processors to collect data on our behalf, such as our payment processor partners.
Cenith Innovations processes the following personal data categories about device and application Users:
Contact information such as email address or physical address.
User information such as gender, height and weight, User ID, and other information you may provide to us about yourself or your account.
Device information such as IP address and location data.
User-provided activity and contextual information such as the activities, notes, comments, and tags you provide within our applications.
Measured data such as heart rate, movement data, and temperature data provided by 3rd party biometric sources authorized by you.
Please note that some of the personal data we process, including any data concerning your health, is considered special or sensitive personal data. Under applicable law, such data is processed only if you have given your consent for processing. If you access or use any of Cenith Innovations’s Applications or Website that support 3rd party integration containing location information, such as by enabling GPS-based activity tracking through Cenith Innovations applications or connected biometric devices, Cenith Innovations may process the approximate or precise location of your device while the service is active. This data may be obtained via your device’s service provider network ID, GPS, and/or Wi-Fi data. Cenith Innovations does not process such location data without first obtaining your consent. You may disable such location processing at any time using your device’s location permission settings.
Contract
When processing personal data to handle and deliver your purchases, we rely on the legal basis of a user contract, which is created when you request access to Cenith Innovations applications.
Consent
We process your personal data for electronic direct marketing purposes if you have provided your consent for it.
Legitimate Interest
When we process your personal data for customer service purposes, marketing, and developing our products, we do it on the basis of our legitimate interest to run, maintain, and develop our business and to create and maintain customer relationships. When choosing to use your data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy under applicable laws.
Legal obligation
Cenith Innovations must process certain information to comply with statutory obligations which may vary in each country. For example, such obligations can relate to consumer protection or accounting legislation.
PROCESSED DATA AND DATA SOURCE
In most cases, we collect personal data directly from you if you choose to complete orders in our online store or contact us with a question or complaint. When you visit Cenith Innovations’s website, we collect analytical data about you via your device and browser via cookies and various other technologies for service development and advertising purposes. Cenith Innovations may also rely on trusted third party processors to collect data on our behalf, such as our payment processor partners. We process the following personal data categories about the website and online store visitors:
Contact information such as name, email address and address
Delivery information such as your purchases and chosen payment method
Device information such as IP address, time of visit, and location data
User activity such as browsing patterns on the site and any communications you have with us.
CALIFORNIA RESIDENTS
CCPA NOTICE FOR CALIFORNIA CONSUMERS
This notice supplements the information contained in Cenith Innovations’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“customers” or “you”), and who access Cenith Innovations’s website or the services provided by Cenith Innovations. This notice is pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this notice.
COLLECTION, USE, AND SHARING OF INFORMATION
Where a customer interacts with Cenith Innovations’s products and/or services, Cenith Innovations collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). Information about the categories of personal information we collect, the purposes for which your personal information is processed, and any sharing of your personal information can be found from relevant sections of this Privacy Policy above:
Application Users: categories of collected personal information and processing purposes
Website Visitor: categories of collected personal information and processing purposes
Sharing of personal data
In the preceding twelve (12) months, we have not sold personal information to third parties, including data aggregators. We have collected and disclosed only the categories of personal information in this Privacy Policy as described in the Data Sharing and Disclosures section below.
CALIFORNIA CONSUMER RIGHTS
If you are a California resident, you have certain rights under the CCPA:
Right to know about the personal information we collect and share
The CCPA gives you the right to request that we disclose the personal information we have collected about you over the past 12 months, which we do after we receive and validate your request. Once we receive and confirm your verifiable consumer request, we will disclose to you:
The categories of personal information we collected about you;
The categories of personal information we have disclosed about you (if any);
The categories of sources for the personal information we collected about you;
Our business or commercial purposes for collecting or selling that personal information;
The categories of third parties with whom we share that personal information; and
The specific pieces of personal information we collected about you.
Right of deletion
You have the right to request erasure of your personal information, subject to certain exceptions, such as when we have a legal obligation to retain the data in question. After we receive and validate your request, we will delete your personal information, as well as direct our service providers to delete your personal information unless an exception applies.
How to make disclosure, access, correction, or deletion requests
If you are a California resident, you can request disclosure, access to, correction, and/or deletion of your personal data as described above by submitting a verifiable consumer request to us by:
Sending an e-mail to DataProtection@CenithInnovations.com, including the following information along with your request: your full name, company name (if applicable), address, e-mail address, and a phone number. We may request that you provide additional information if necessary to confirm your identity. This is for security purposes, and is required by law in some cases.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You have the right to make a free request up to two times in any 12-month period. We will respond to all validated requests within 45 days of receiving your request, unless we request an extension. In the event that we reasonably require an extension in order to respond to your request, we will notify you of any such extension within the initial 45-day period.
Non-Discrimination
Cenith Innovations does not discriminate against users who request to exercise their privacy rights under the CCPA. Unless an exception applies, this includes our promise not to:
Deny you goods or services;
Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services; or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
DATA SHARING AND DISCLOSURES
PERSONAL DATA SHARING
Cenith Innovations does not sell or rent your personal information, and only shares your personal data with certain trusted service providers and partners so that we can provide and improve our services, to provide partner services and other offerings, and to operate our business. Whenever we share data with third-party service providers, we require that they use your information only for the purposes we’ve authorized, and for the limited reasons explained in this Privacy Policy. We also require these service providers to protect your personal information to at least the same standards that we do.
Like most companies, Cenith Innovations uses service providers for purposes such as:
providing and improving our online service platform;
storing our users’ data;
providing customer services;
managing and organizing our marketing activities. Cenith Innovations only shares website usage data with our advertising network partners for the purposes of analyzing and optimizing our marketing. Cenith Innovations does not share the Cenith Innovations App data with third party advertisers; and
analyzing information regarding the use of our online service to improve our service quality.
Cenith Innovations stores personal data primarily within the geographic region in which it is collected. In cases where personal data is processed outside of the area in which it was collected, we always ensure your personal data is protected with appropriate safeguards in accordance with applicable privacy laws. We also use industry standard data protection measures to safeguard all international transfers of personal data through data protection agreements with our service providers.
PERSONAL DATA DISCLOSURES
We also reserve the right to disclose personal information under certain specific circumstances, including:
When we have your express consent to do so;
When it is reasonably necessary for our legitimate interests in conducting our business, such as in the event a merger, acquisition, or sale;
To protect Cenith Innovations’s legal rights and property; and
To comply with valid legal requirements. Cenith Innovations will oppose any request to provide legal authorities with access to user data for surveillance or prosecution purposes, and will notify users if we receive any such request.
Otherwise, your personal information is never shared with any individual or other organization.
SAFEGUARDING YOUR DATA
Cenith Innovations uses technical and organizational safeguards to keep your data safe and secure. When appropriate, these safeguards include measures such as anonymization or pseudonymization of personal data, strict access control, and the use of encryption to protect the data we process.
We also ensure that our staff receive adequate training to ensure personal data is processed only in accordance with our internal policies, consistent with our obligations under applicable law. We also limit access to your sensitive personal data to personnel that have specifically been granted such access.
Online services that Cenith Innovations provides protect your personal data in-transit using encryption and other security measures. We also regularly test our service, systems, and other assets for possible security vulnerabilities.
We update Cenith Innovations Applications regularly. We recommend that you make sure that you always have the latest app and firmware versions installed in order to maximize protection of your data.
DATA RETENTION
The retention period for your personal data generally depends on the duration of your Cenith Innovations account lifecycle. Your personal data will be deleted when it is no longer needed for the purpose for which it was originally collected, unless we have a legal obligation to retain data for a longer period of time.
Cenith Innovations also has legal obligations to retain certain personal data for a specific period of time, such as for tax purposes. These required retention periods may include, for example, accounting and tax requirements, legal claims, or for any other legal purposes. Please note that obligatory retention periods for personal data vary based on the relevant law.
If you wish, you may request deletion of your Cenith Innovations account by contacting DataProtection@CenithInnovations.com.
USE OF COOKIES
We use cookies and various other technologies to collect and store analytics and other information when customers use our site, as well as for personalization and advertising purposes. The cookies we use include both first party and third party cookies.
Cookies are small text files sent and saved on your device that allows us to identify visitors of our websites and facilitate the use of our site and to create aggregate information of our visitors. This helps us to improve our service and better serve our customers, and will not harm your device or files. We use cookies to tailor our site and the information we provide in accordance with the individual interests of our customers. Cookies are also used for tracking your browsing habits and for targeting and optimizing advertising, both on our site as well as on other sites you may visit. We also use cookies for integrating our social media accounts on our website.
Please see our Cookie Policy for more information on Cenith Innovations’s use of cookies, and how you can set your cookie preferences.
YOUR RIGHTS AS A DATA SUBJECT
Whenever Cenith Innovations processes your data, you have certain rights that enable you to control how your personal data is being processed. This section provides you with information about each of those rights. If you wish to exercise your rights as a data subject, please contact DataProtection@CenithInnovations.com with your request to do so.
Right to access data
You have the right to know what personal data is processed about you. You may contact us to request access to the personal data we have collected about you, and we will confirm whether we are processing your data, and provide you with information about the personal data we have collected and processed.
Right to erasure
You have the right to request the deletion of your personal data in certain circumstances. We will comply with such requests unless we have a valid legal basis not to do so, or a legal obligation to preserve the data.
Right to rectification (of inaccurate data)
You have the right to request correction of any incorrect or incomplete personal data we have stored about you.
Please note that you can correct and update some of your basic information via Cenith Innovations Applications.
Right to data portability
You have the right to request receipt of the personal data you have provided to us in a structured and commonly used format. The right to data portability only applies when we process your personal data for certain reasons, such as by contract or by your consent.
Right to object to processing
You have the right to object to the processing of your personal data under certain circumstances. In the event that we do not have legitimate grounds to continue processing such personal data, we will no longer process your personal data after we have received and verified your objection. You also have the right to object to the processing of your personal data for direct marketing purposes at any time.
Right to restrict processing
You have the right to request that we restrict processing some types of personal data under certain circumstances. For example, if you contest the accuracy of your data, you can make a restriction request that we do not process your data until Cenith Innovations has verified the accuracy of your data.
Right to withdraw consent
If we have requested your consent in order to process your personal data, you have the right to withdraw your consent for such processing at any time. It should be noted, however, that withdrawing your consent may lead to issues or restrictions on your ability to fully utilize Cenith Innovations services.
Please note that you can always unsubscribe from receiving our newsletter and other marketing emails by using the ‘Unsubscribe’ link provided in the emails you receive from us.
Cenith Innovations strives to address your privacy concerns. If you have contacted Cenith Innovations about your issue and are still unhappy with our response, subject to applicable law, you may contact your local supervisory authority regarding your issue. However, we urge you to first contact us at DataProtection@CenithInnovations.com so that we can more quickly resolve your issue before escalating the issue.
Please read Cenith Innovations’s CCPA Privacy Notice if you are a resident of the state of California to read more about your rights under California law.
CONTROLLER CONTACT INFORMATION
Cenith Innovations is the data controller for all processing purposes. Please find our contact details below:
Cenith Innovations
Address: 1861 9TH AVE SACRAMENTO, CA 95818
Data Protection Officer: DataProtection@CenithInnovations.com
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this Policy from time to time at our sole discretion, but if we do, we’ll let you know about any material changes either by notifying you on the website or by sending you an email or push notification. If you keep using Cenith Innovations services after a change, your continued use means that you accept any such changes.
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