Legal

Privacy Policy

What we collect, why, and who sees it — in plain language. Short version: we never sell your health data.

Effective date: 14 August 2026 · Version: 1.0

1. Who we are

CyclePlate is operated by The Bett Collective Limited ("CyclePlate," "we," "us," "our"), a company registered in Kenya. We provide a mobile application that delivers phase-based nutrition guidance aligned to your menstrual cycle.

Data controller: The Bett Collective Limited
Contact: cycleplateprivacy@gmail.com
Registered address: Safari Business Arcade, Thika Road, Roysambu, Kasarani, P.O. Box 00618, Nairobi, Kenya

We are registered as a data controller with the Office of the Data Protection Commissioner (Kenya).

2. Privacy at a glance — data nutrition label

A plain summary of every category of data we collect, what we do with it, and whether you must provide it. Full detail follows in the sections below.

DataWhat exactlyWhyShared externally?Required?Kept untilBirth yearYear of birth onlyAge verification (18+)NoYes — hard gateAccount deletionName / nicknameFirst name or chosen namePersonalisationNoNo — skippableAccount deletionEmail addressYour emailAccount login, communicationsNoYesAccount deletionCycle dataLast period date, cycle length, period lengthPhase calculation — core serviceNoYes — core feature30 days after deletionHealth logsMood, energy, sleep, symptoms, flowPersonalised recommendationsNoNo — optional30 days after deletionFood logsMeals logged, saved recipes, meal plansPersonalised recommendationsNoNo — optional30 days after deletionCuisine preferenceCuisine type selectedAI meal personalisationAnonymised input to AI providerYes — core feature30 days after deletionDietary restrictionsAllergies, intolerances, eating styleAI meal safety filteringAnonymised input to AI providerNo — optional30 days after deletionLocation (country)Country or region onlyCurrency, localisation, complianceNoYes30 days after deletionConsent recordsTimestamps, checkbox states, versionLegal complianceNoAutomatic7 yearsDevice / technicalDevice type, OS, app versionService reliabilityCrash reporting provider (anonymised)Automatic90 daysUsage analyticsFeatures used, session lengthProduct improvementAnalytics provider (anonymised)Automatic — opt-out available90 daysSubscription statusActive/inactive, plan typeFeature access controlApple App Store / Google Play onlyAutomaticDuration of account

Key: We never sell health data. We never share identifiable health logs. AI providers receive only anonymised preference inputs (cuisine, dietary restrictions, current phase) — never your name, email, period dates, or symptom logs.

3. Scope of this policy

This policy applies to all personal data we collect through the CyclePlate mobile application, our website, and any related services. It applies regardless of where you are located.

This policy does not apply to third-party services linked from our app. We encourage you to read their privacy policies separately.

4. The data we collect

We collect only what we need to provide the service. Below is a complete list.

4.1 Data you give us directly

CategorySpecific dataWhy collectedIdentityFirst name or nicknamePersonalisationContactEmail addressAccount creation, communicationsAgeBirth yearAge verification (18+ requirement)Cycle dataLast period date, cycle length, period length, phase historyCore service — phase calculationHealth and wellbeingMood logs, energy levels, sleep logs, symptom entries, flow logsPersonalised recommendationsFood and nutritionMeal logs, saved recipes, planned meals, cuisine preference, dietary restrictions/allergiesPersonalised recommendationsPreferencesCuisine preference, dietary preference, notification settings, display settingsService personalisationLocationCountry/region (for currency and localisation)Payment and complianceConsent recordsTimestamps, version numbers, checkbox states for T&C and health data consentLegal compliance

4.2 Data we collect automatically

CategorySpecific dataWhy collectedTechnicalDevice type, operating system version, app versionService reliabilityUsageFeatures used, session length, screens visitedApp improvementCrash dataError logs, stack tracesBug fixingAnalyticsAggregated, anonymised usage patternsProduct improvement

4.3 Data we do not collect

We do not collect:

  • Precise GPS location
  • Contacts or address book
  • Camera or microphone data
  • Financial data (payments processed directly by the Apple App Store or Google Play)
  • Biometric data

5. Legal basis for processing

We process your data only where we have a lawful basis to do so. The basis varies by jurisdiction and by type of data.

5.1 All markets

Processing activityLegal basisAccount creation and managementContractual necessityDelivering phase-based nutrition guidanceContractual necessityHealth and cycle data processingExplicit consent (obtained at onboarding)Sending notifications you enableConsentCrash reporting and securityLegitimate interestsLegal complianceLegal obligation

5.2 Kenya (Data Protection Act 2019)

We process your health data as sensitive personal data under Section 46 of the Kenya Data Protection Act 2019, on the basis of your explicit consent given at onboarding. You may withdraw consent at any time by deleting your account.

We have registered as a data controller with the Office of the Data Protection Commissioner (ODPC) as required by the Act.

We note the provision of Section 30 of the Kenya DPA 2019 which states health data may only be processed by or under the responsibility of a health care provider. Our nutrition content is reviewed by a registered dietitian who holds professional responsibility for the framework. We have sought local legal advice to confirm this satisfies the provision.

5.3 South Africa (POPIA — Protection of Personal Information Act 4 of 2013)

Your health data constitutes special personal information under POPIA. We process it on the basis of your explicit consent (Condition 1) and for the purpose of providing the service you requested (Condition 2).

5.4 Nigeria (Nigeria Data Protection Act 2023)

We process your sensitive personal data on the basis of explicit consent as required by the NDPA 2023. We have assessed our status as a data controller and will register with the Nigeria Data Protection Commission where required.

5.5 United Kingdom and European Union (UK GDPR / EU GDPR)

For users located in the UK or EU, our lawful bases are:

  • Consent — for health and cycle data, and for marketing communications
  • Contract — for delivering the service you signed up for
  • Legitimate interests — for security, fraud prevention, and product improvement, where these do not override your rights

You have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

6. How we use your data

We use your data only for the purposes stated. We do not use your identifiable health data to train AI models.

PurposeData usedBasisCalculate your current cycle phaseCycle dataContractGenerate phase-aligned meal suggestionsCycle data, cuisine, dietary preferencesContractPersonalise daily nudges ("Today's One Thing")Cycle data, check-in historyContractBuild and update your 7-day meal planAll food and cycle dataContractGenerate your grocery listMeal planContractSend phase transition notificationsCycle dataConsentImprove the AI recommendation frameworkAnonymised, aggregated data onlyLegitimate interestsMaintain security and prevent fraudTechnical and usage dataLegitimate interestsComply with legal obligationsAs requiredLegal obligation

We never:

  • Sell your personal data
  • Share your health data for advertising purposes
  • Use your identifiable data to train third-party AI models
  • Share your data with employers, insurers, or government bodies unless required by law

7. AI processing and automated decision-making

7.1 How AI is used

Meal suggestions, weekly plans, and daily nudges are generated by an AI system using your cycle phase, cuisine preference, and dietary restrictions as inputs. The AI framework has been reviewed and approved by a registered dietitian.

7.2 AI provider

Our AI suggestions are powered by Google Gemini. Relevant preference data (cuisine, dietary restrictions, current phase) is sent to the Gemini API to generate suggestions. We do not send your name, email, identifiable health logs, or period dates to Google Gemini.

You can review Google's privacy policy at https://policies.google.com/privacy.

7.3 Automated decision-making

CyclePlate uses automated systems to generate food suggestions. These suggestions do not constitute medical decisions and carry no legal or similarly significant effect on you. You are not subject to automated decision-making in the legal sense under GDPR Article 22 or equivalent provisions.

7.4 Opting out

AI features — including meal suggestions, weekly plans and daily nudges — are part of CyclePlate Plus. Before you start Plus or a Plus trial, we ask for your separate consent to send your current phase, cuisine and dietary restrictions to our AI provider. If you do not consent, you cannot use Plus features, but you can keep using the free tier, which does not use AI processing. You can withdraw this consent at any time in You → Data & privacy.

8. Sharing your data

8.1 We share data with

RecipientPurposeSafeguardCloud infrastructure provider (e.g., Firebase / Supabase)Database, authentication, storageData processing agreement in placeAI provider (Google Gemini)Generating meal suggestionsAnonymised inputs; no health logs shared; DPA in placePush notification service (e.g., Firebase Cloud Messaging)Delivering notificationsNo health data sharedAnalytics and crash reporting providerApp reliability and improvementAnonymised/aggregated data onlyApple App Store and Google PlayPayment processingPayment data handled entirely by Apple or Google; we receive only subscription statusLegal authoritiesWhere required by applicable lawOnly to the extent required

8.2 Partner Mode

If you activate Partner Mode, you choose specifically what your partner can see (current phase, energy level, today's foods). Your exact period dates, symptom details, personal notes, and meal history are always excluded from Partner Mode. You can revoke partner access at any time.

8.3 Business transfers

If CyclePlate is acquired or merged, your data may be transferred to the new entity. We will notify you before any such transfer and give you the opportunity to delete your account.

9. International data transfers

Your data may be stored and processed outside your country of residence, including in the United States and European Union, where our infrastructure providers operate.

Where we transfer data outside your jurisdiction, we apply appropriate safeguards:

  • Kenya: We seek to minimise cross-border transfers. Where transfers occur, we use contractual agreements that protect your rights under the Kenya DPA 2019.
  • South Africa: International transfers comply with Section 72 of POPIA. We use binding agreements with recipients to ensure equivalent protection.
  • Nigeria: International transfers comply with the NDPA 2023. We use data processing agreements with international recipients.
  • EU/UK: International transfers use Standard Contractual Clauses (SCCs) approved by the European Commission, or UK IDTA where applicable.

10. Data retention

We keep your data for as long as your account is active. When you delete your account:

Data categoryRetention after deletionHealth and cycle dataDeleted within 30 daysMeal logs and preferencesDeleted within 30 daysAccount information (name, email)Deleted within 30 daysConsent recordsRetained for 7 years (legal obligation)Financial/subscription recordsRetained as required by applicable tax law (typically 5-7 years)Anonymised analyticsMay be retained indefinitely (not linked to you)Crash logsDeleted within 90 days

We do not retain your data for longer than necessary for the purpose it was collected.

11. Security

We protect your data through:

  • Encryption in transit (TLS 1.2 or higher)
  • Encryption at rest (AES-256 or equivalent)
  • Access controls limiting which team members can access personal data
  • Regular security assessments
  • Secure deletion procedures

Data breach notification: If we suffer a breach that is likely to result in risk to your rights, we will notify:

  • The relevant supervisory authority within 72 hours of becoming aware
  • Affected users without undue delay where the breach is high-risk

No system is perfectly secure. If you believe your account has been compromised, contact cycleplatesecurity@gmail.com immediately.

12. Your rights

Your rights depend on where you are located. We honour all of the following:

RightWhat it meansHow to exerciseAccessObtain a copy of your personal dataYou → Data & privacy → Export my data, or email cycleplateprivacy@gmail.comRectificationCorrect inaccurate dataYou → Accounts & preferences → Save profileErasureDelete your account and all associated dataYou → Accounts & preferences → Delete my account, or email cycleplateprivacy@gmail.comPortabilityReceive your data in a machine-readable formatYou → Data & privacy → Export my dataObjectionObject to processing based on legitimate interestsEmail cycleplateprivacy@gmail.comRestrictionRestrict how we process your data while a dispute is resolvedEmail cycleplateprivacy@gmail.comWithdraw consentWithdraw consent for health data processing at any timeDelete your account

We will respond to all requests within 30 days. We will not charge a fee for exercising your rights unless requests are manifestly unfounded or excessive.

13. Regulatory authorities

If you are not satisfied with our response to a privacy concern, you have the right to complain to your local supervisory authority:

  • Kenya: Office of the Data Protection Commissioner (ODPC) — odpc.go.ke
  • South Africa: Information Regulator — inforegulator.org.za
  • Nigeria: Nigeria Data Protection Commission (NDPC) — ndpc.gov.ng
  • UK: Information Commissioner's Office (ICO) — ico.org.uk
  • EU: Your local data protection authority (list at edpb.europa.eu)

14. Minimum age

CyclePlate is for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we become aware that a user is under 18, we will delete their account and all associated data promptly.

If you believe a person under 18 has created an account, please notify us at cycleplateprivacy@gmail.com.

15. Cookies and tracking

The CyclePlate mobile app does not use browser cookies. We use:

  • Analytics SDK — to understand how features are used (anonymised). You can opt out in You → Data & privacy → Anonymous analytics.
  • Crash reporting SDK — to identify and fix errors. This cannot be disabled as it is essential to service reliability.

We do not use advertising trackers or share data with ad networks.

16. Changes to this policy

We will notify you of material changes to this policy by:

  • Sending an in-app notification
  • Updating the effective date at the top of this document

Continued use of the app after a change constitutes acceptance. If you do not accept the updated policy, you may delete your account.

17. Contact us

Privacy queries: cycleplateprivacy@gmail.com
Data deletion requests: cycleplateprivacy@gmail.com
Security concerns: cycleplatesecurity@gmail.com
General support: cycleplatesupport@gmail.com
Postal address: Safari Business Arcade, Thika Road, Roysambu, Kasarani, P.O. Box 00618, Nairobi, Kenya

This policy is written in plain language for accessibility. It is a legally binding document. The plain-language footer note on the in-app version is supplementary only.