Privacy Policy

This Privacy Policy explains how Lence ("Lence," "we," "us," or "our") collects, uses, discloses, and protects information when you use our mobile application and related services (collectively, the "App"). It applies to users worldwide, with additional rights described for residents of the European Economic Area ("EEA"), the United Kingdom, Switzerland, the United States, Canada, Nigeria, South Africa, Kenya, and other jurisdictions with applicable data protection laws.

We built Lence around a privacy-first, on-device AI architecture. This Policy is intended to explain that architecture and your rights in plain language. Please read it carefully. By creating an account or using the App, you acknowledge that you have read and understood this Policy.

1. Who We Are and How to Contact Us

Lence is operated by Innovative Labs, a company registered in England and Wales with its registered address at Manchester, United Kingdom.

Data Protection contact: support@lence.fit . We have not appointed a dedicated Data Protection Officer, as this is not currently required for our organization under applicable law. If our data processing activities change such that a DPO becomes required (for example, under Article 37 GDPR), we will appoint one and update this Policy with their contact details.

General privacy inquiries: support@lence.fit

2. Categories of Information We Collect

2.1 Information You Provide Directly

• Account information: name, email address, password (or Sign in with Apple/Google identifiers), profile photo.

• Onboarding responses: primary wellness goal (e.g., activity, stress, sleep), self-reported activity level.

• Community content: group names, member lists, in-app "cheers," and any content you choose to share within a private group.

• AI Companion conversations: messages you send to the in-app AI chat feature, and the AI's responses.

• Customer support correspondence.

2.2 Information Collected Automatically

• Motion and fitness data (steps, activity type, general movement patterns) via device sensors and, where you connect them, Apple Health or Google Fit.

• Device and technical data: device type, operating system, unique device identifiers, app version, crash logs, and general diagnostic data.

• Usage data: features used, screens viewed, session length, and interaction patterns, used to improve the App.

• Approximate location data, only if you separately enable location-based features (if applicable).

2.3 Special Category / Sensitive Data

Steps, activity levels, sleep-related insights, and similar wellness metrics may constitute "special category data" under Article 9 GDPR, "sensitive personal information" under applicable U.S. state laws (e.g., CCPA/CPRA), or equivalent categories under African data protection statutes (e.g., Nigeria's NDPA, South Africa's POPIA). We treat this data with heightened care as described in Sections 4, 6, and 9 below.

2.4 Local Storage vs. Optional Cloud Sync — Your Choice

By default, your raw sensor data (motion, steps, and similar signals) is processed and stored locally on your device using on-device AI models. This data remains yours and is not automatically transmitted to or stored on our servers.

Certain features are optional and require some data to be saved to our servers ('Cloud Sync') because they cannot work on a single device alone, including: syncing your data across multiple devices; backing up your data so it is not lost if you lose or replace your device; participating in Community groups, shared challenges, and leaderboards; and receiving AI-generated insights that reference your history over time. You choose whether to enable these features. Where you do not enable Cloud Sync, data kept solely on your device is under your control, and we cannot recover it for you if it is lost — for example, if your device is lost, stolen, damaged, reset, or the App is uninstalled. We are not responsible for the loss of data that exists only on your device and was never synced to your account.

You may review and change what is synced at any time in Settings > Connected Services & Data, and may delete synced data from our servers at any time, subject to Section 7 (Data Retention).

2.5 Use of Data for Research and Product Development

With your consent, we may use de-identified or aggregated data derived from your activity to conduct research intended to improve the accuracy of our AI models, validate new wellness features, and better understand general activity and wellness trends. Where we conduct such research:

• We prioritize using data that has been aggregated or de-identified so that it can no longer reasonably be linked back to you;

• Where research requires data that is not fully de-identified (for example, to track patterns for a single user over time), we will only use it for this purpose with your separate, explicit opt-in consent, which you may withdraw at any time via Settings > Privacy > Research Participation without affecting your ability to use the core App;

• We will never sell data used for research purposes to third parties, and any research collaboration with an external academic or commercial partner will be subject to a data protection agreement and, where required by law, further notice to you;

• You may decline participation in research at any time; declining will never restrict your access to core App features.

This use of data for research is separate from, and in addition to, our use of aggregated analytics to maintain and debug the App described in Section 3, which does not require separate consent as it is necessary for the App to function.

3. How We Use Your Information

We use the categories of information described above for the following purposes, consistent with the principle of data minimization:

• To create and administer your account and authenticate you (including biometric login, which is processed on-device and never transmitted to us).

• To generate personalized, AI-driven insights about your activity, and to power the AI Companion chat feature.

• To operate community groups, challenges, leaderboards, streaks, and achievement badges.

• To send notifications you have opted into (daily insights, community updates, streak reminders).

• To maintain, secure, debug, and improve the App, including through aggregated and de-identified analytics.

• To provide customer support and respond to inquiries.

• To comply with legal obligations, enforce our Terms & Conditions, and protect the rights, safety, and property of Lence, our users, and the public.

• To provide the Augmented Reality data visualization feature, which uses your device camera and motion sensors solely to detect flat surfaces for rendering; camera imagery is processed on-device in real time and is not recorded, stored, or transmitted to our servers.

We do not use your health or wellness data to serve targeted third-party advertising, and we do not sell your personal data.

4. Legal Bases for Processing (EEA/UK Users)

Where the GDPR or UK GDPR applies, we rely on the following legal bases:

• Consent (Article 6(1)(a) and, for special category wellness data, Article 9(2)(a)) — for processing motion/fitness data, sending marketing communications, and enabling optional features such as location or camera access. You may withdraw consent at any time via Settings, without affecting the lawfulness of processing before withdrawal.

• Performance of a contract (Article 6(1)(b)) — for account creation, core app functionality, and community features.

• Legitimate interests (Article 6(1)(f)) — for security, fraud prevention, product improvement, and de-identified analytics, balanced against your rights and interests.

• Legal obligation (Article 6(1)(c)) — where we must retain or disclose information to comply with law.

5. Sharing and Disclosure of Information

We do not sell your personal information. We may share information only in the following circumstances:

• Service providers / processors: cloud hosting, analytics, customer support, and notification delivery vendors, bound by data processing agreements and instructed only to process data as we direct.

• Community members: information you choose to share within a private group (e.g., your name, streaks, and cheers) is visible to other members of that specific group only, never publicly.

• Legal and safety reasons: where required by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of Lence, our users, or others.

• Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to continued protection of your information under a policy at least as protective as this one.

• With your consent: for any other purpose disclosed to you at the time of collection and to which you agree.

6. International Data Transfers

Lence's on-device-first architecture minimizes cross-border transfer of raw sensitive data. Where derived or account data is transferred internationally (for example, to cloud servers located outside your country of residence), we implement appropriate safeguards, including the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or equivalent mechanisms recognized under applicable African and other data protection frameworks, to ensure your information receives an adequate level of protection wherever it is processed.

7. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements. As a general guide:

• Account and profile data: retained while your account is active, and for 7 days following account deletion to allow for recovery, unless a longer period is required by law.

• Wellness and activity data: retained per your in-app settings; you may delete historical data at any time via Settings > Account.

• AI Companion conversation logs: retained for 7 days to improve model performance and for safety review, unless you delete them sooner, after which they are deleted or irreversibly de-identified.

• Support correspondence and legal records: retained as required for legal, accounting, or regulatory purposes.

8. Your Privacy Rights

8.1 Rights for EEA, UK, and Switzerland Residents (GDPR)

You have the right to: access your personal data; rectify inaccurate data; erase your data ("right to be forgotten"); restrict or object to processing; data portability; and to lodge a complaint with your local supervisory authority (e.g., the ICO in the UK, or your national Data Protection Authority in the EU).

8.2 Rights for U.S. Residents (CCPA/CPRA and similar state laws)

Depending on your state of residence (including but not limited to California, Colorado, Connecticut, Virginia, and Utah), you may have the right to know what personal information we collect, request deletion, correct inaccurate information, opt out of the sale or "sharing" of personal information (we do not sell or share your data for cross-context behavioral advertising), and to non-discrimination for exercising these rights. We do not knowingly sell or share sensitive personal information, including health and wellness data.

8.3 Rights for Canadian Residents (PIPEDA)

You have the right to access and request correction of your personal information, and to withdraw consent for its collection, use, or disclosure, subject to legal or contractual restrictions.

8.4 Rights for Nigerian Residents (Nigeria Data Protection Act 2023)

You have the right to be informed, to access your data, to rectification, to erasure, to restrict processing, to data portability, and to object to processing, and may lodge complaints with the Nigeria Data Protection Commission.

8.5 Rights for South African Residents (POPIA)

You have the right to access, correct, and delete your personal information, to object to processing, and to lodge a complaint with the Information Regulator of South Africa.

8.6 Rights for Other Jurisdictions

If you reside in a jurisdiction with its own data protection law not specifically listed above (including other African Union member states, Latin American, or Asia-Pacific jurisdictions), we will honor requests consistent with applicable local law. To exercise any of the above rights, contact us at support@lence.fit . We will respond within the timeframe required by applicable law.

9. Health Data — Special Handling

Because Lence processes wellness-related information, we apply additional safeguards:

• On-device processing by default for raw sensor data (Section 2.4).

• Encryption of derived health-related data both in transit (TLS 1.2+) and at rest (AES-256 or equivalent).

• Access to health-related data within our organization is restricted to personnel with a legitimate operational need, subject to confidentiality obligations.

• We do not use wellness data to make automated decisions producing legal or similarly significant effects on you without human oversight.

• Any use of identifiable wellness data for research (Section 2.5) requires your separate opt-in consent, which is off by default and may be withdrawn at any time.

Lence is a wellness and productivity companion, not a medical device. It does not diagnose, treat, cure, or prevent any disease, and AI-generated insights are not medical advice. See the Terms & Conditions for full disclaimers.

10. Children's Privacy

The App is not directed at, and is not intended for use by, individuals under the age of 16 (or the minimum age of digital consent in your jurisdiction, if higher, e.g., 13 in parts of the United States under COPPA where applicable, or as otherwise set by EU member state law). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child in violation of this Policy, we will take steps to delete such information promptly. Parents or guardians who believe their child has provided us with personal information should contact us at support@lence.fit

11. Security

We implement industry-standard technical and organizational measures, including encryption, access controls, secure development practices, and regular security review, designed to protect your information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

12. Cookies and Similar Technologies

Our App and any associated website may use cookies, SDKs, and similar tracking technologies for authentication, analytics, and functionality. Where required by law, we will request your consent before deploying non-essential cookies or trackers, and you may manage your preferences via your device or browser settings.

13. Third-Party Services and Links

The App may integrate with third-party services such as Apple Health, Google Fit, Apple/Google Sign-In, and push notification providers. Your use of those services is governed by their own privacy policies, and we encourage you to review them. We are not responsible for the privacy practices of third parties.

14. Automated Decision-Making

The "Insight for You" feature and AI Companion generate content using automated processing of your activity data. These insights are informational and supportive in nature, do not produce legal or similarly significant effects, and are always presented for your voluntary consideration rather than as binding decisions about you.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. We will notify you of material changes through the App or by email, and will indicate the "Last Updated" date above. Your continued use of the App after changes take effect constitutes acceptance of the revised Policy, to the extent permitted by applicable law; where required, we will obtain your renewed consent.

16. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us at:

Lence Fit

Manchester, United Kingdom.

Email: support@lence.fit