Version 2.0 — effective October 25, 2026
This Policy explains what data we process, why, on what legal basis, who we share it with and how to exercise your rights. It applies to the Nivel 100 app, its websites and services. We do not sell your data.
1. Controller
Nivel Cien Group, based in Chile. Privacy contact: soporte@nivelcien.lat.
2. What data we process
- Account: first name, last name, username, email and password (stored encrypted). If you sign in with Google, Facebook or Microsoft, we receive your name, email and photo.
- Profile: country, region and city, date of birth, gender identity (optional), reference sex for calculations, language, time zone and body measurements (optional).
- Training and activity: workouts, sets, records, sports, steps, saved routes and performance metrics. If you train at a gym that uses Nivel 100 and scan a machine, the machine used.
- Health data (special or sensitive category): meals, water, recipes, fasting, supplements, weight and body fat, progress photos, what you log in Damage Control, and Health Connect data if you turn on sync.
- Location: precise only while you use a feature that needs it (section 6); approximate (city or region) from your IP or your device.
- Device and usage: model, operating system, app version, IP, device and advertising identifiers, usage events and error reports.
- Social: friends, clan, participation in challenges and Raids, and your relationship with your Sensei.
- Purchases: plan, purchase history and subscription status (never your card details).
- Acceptance of documents: which version of these texts you accepted, when, in which language, and from which IP and device.
- Support: what you write to us and the error reports you send.
3. What we use your data for and on what legal basis
| Purpose | Data | Legal basis |
|---|---|---|
| Create and maintain your account, provide the Service and its features | Account, profile, training | Performance of the contract (the Terms) |
| Log and analyze your nutrition, weight, fasting, supplements and Damage Control | Health data | Explicit consent, which you can withdraw |
| Sync with Health Connect | Health Connect data | Explicit consent (given when you turn it on) |
| Features that use precise location | Precise location | Consent (phone permission) |
| Show you challenges, gyms and content in your area, and the weather for the Shadow | Approximate location | Legitimate interest in offering local content |
| Automatic suggestions (routines, macros, reminders) | Training, health | Contract and, for health data, consent |
| AI features (food photo, routines, translation) | Only the photo or text you send | Contract (you use them) |
| Charge plans and purchases | Purchases | Contract and tax obligations |
| Ads on free plans | Advertising identifier, approximate location | Consent where the law requires it (EU, UK); legitimate interest elsewhere |
| Measure app usage and campaigns | Usage events, identifiers | Consent where the law requires it; legitimate interest elsewhere |
| Account emails | Contract | |
| Promotional emails | Consent; unsubscribe in every email | |
| Security, fraud and cheating prevention, and error reports | Device, IP, usage | Legitimate interest |
| Proving that you accepted these texts | Acceptance record | Legal obligation and legitimate interest |
We never use your health, nutrition or Damage Control data to target ads, and we never share it with advertisers.
4. Automated decisions
The adaptive engine, the Shadow’s reminders and the suggestions are calculated with automatic rules. They only suggest: none of them changes your plan, your goals or your account without your acceptance, and none has legal effects on you.
5. Health data
- You use it to keep your own records. You can stop logging it or delete it at any time.
- Progress photos are stored encrypted and only your account can see them: never a Sensei, a gym or Nivel 100 staff.
- A Sensei you accept sees your training and progress metrics, never your photos.
- Health Connect: we read steps, calories, distance, heart rate, sleep, weight, body fat and exercise sessions; we write your workouts and meditations. This data is not used for advertising, not sold and not shared with third parties. Turn it off in Settings → Health sync or in Health Connect. Nivel 100 complies with the Health Connect requirements of the Google Play policy.
6. Location
- Precise, only while the app is in use and with your permission: Activity routes, GymBro and nearby gyms. It is never shown to other users. Being near a gym never adds it to your list.
- Approximate (city or region): we get it from your IP and, if you already granted location permission, from your device. It is used to show you challenges and content in your area and the Shadow’s weather (Open-Meteo only receives approximate coordinates). We never ask for location permission just for this.
- You can deny or remove the permission in your phone’s settings; the rest of the app keeps working.
7. Advertising and measurement
- Free plans show Google AdMob ads and brand and gym placements labeled “Ad” or “Sponsored”. AdMob may use your advertising identifier. Paid plans show no ads.
- We use Firebase Analytics and AppsFlyer to measure usage and installs, and we send install and purchase events to Meta to measure campaigns.
- In the European Union and the United Kingdom we will ask for your consent before personalized ads and measurement.
- You can reset or delete your advertising identifier in your phone’s settings.
8. Who we share data with
Providers that process data on our behalf, only for their function and under contract:
| Provider | Purpose |
|---|---|
| Google (Firebase, AdMob, Gemini, Google Play, translation) | Notifications, analytics, ads, AI, purchases, sign-in |
| Meta, Microsoft | Sign-in; Meta also measures campaigns |
| RevenueCat | Subscription management |
| AppsFlyer | Install measurement |
| Zoho, Brevo | Account and promotional emails |
| Open Food Facts | Product search (only the text or code searched) |
| Open-Meteo | Weather (only approximate coordinates) |
| Contabo | Hosting of the database and the app |
Others who receive data because you ask for it:
- Advertisers: if you submit an ad’s contact form, that advertiser receives only the details you confirmed in that submission and handles them under its own policy. A coupon does not reveal your identity.
- Your Sensei: your training and progress metrics.
- Your gym: counts and aggregate statistics (machine usage, peak hours), never your personal activity. Exception: it can see that you were detected near its location in order to invite you.
- Other users: your username, avatar, level, cosmetics, the Shadow and your automatic milestones.
- Authorities: only when the law requires us to.
9. International transfers
Some providers process data outside your country (for example in the US or the EU). We use providers that offer adequate safeguards: adequacy decisions or standard contractual clauses approved by the authorities.
10. How long we keep it
| Data | Period |
|---|---|
| Account and everything logged | While the account exists; deleted immediately when you delete it |
| Backups | Overwritten on a rolling basis |
| Guest accounts | 90 days without use |
| Payments | The period required by tax law |
| Record of document acceptance | While the account exists |
| Error reports | Without identifiable data, to improve the app |
11. Your rights
You have the right to access your data, rectify it, erase it, port it, object to processing, restrict or block it and withdraw your consent at any time, without affecting what was done before.
- In the app: export your data for free, edit your profile and records, delete your account (Profile → Legal and privacy), turn off Health Connect, notifications and permissions, and unsubscribe from emails.
- By email: soporte@nivelcien.lat. We reply within 30 days. We may ask you to confirm your identity.
- If you are not satisfied, you can complain to the data protection authority in your country (in Chile, the Personal Data Protection Agency; in the EU, your country’s supervisory authority).
12. Minors
The Service is for people aged 14 or over. Damage Control and social features that put people in contact require you to be 18 and stay locked until you confirm you are an adult. Progress photos are private: only your account can see them. We do not use data from people under 18 for personalized ads. In the European Union, anyone under the age set by their country (between 13 and 16) needs their parent’s or guardian’s permission to log health data. If you know that someone under 14 has given us data, write to us and we will delete it.
13. Security and breaches
- Everything travels encrypted (HTTPS/TLS). Progress photos are stored encrypted. Staff access is limited to what is needed to operate and provide support.
- Security PIN and optional biometrics: biometrics are verified by your phone; we never receive them.
- If a breach puts your data at risk, we will notify the authorities and the affected people within the time limits required by law.
14. Guest mode
If you explore without an account, we create an anonymous account linked to an identifier on your device, with no name or email. If you create an account, what you did as a guest moves to it and the anonymous account is deleted.
15. Information by region
- Chile: we process your data under Law 19.628 and, from December 1, 2026, under Law 21.719. Your rights and how to exercise them are in section 11.
- European Union, European Economic Area and United Kingdom: we apply the GDPR. The legal bases are in section 3 and transfers in section 9.
- United States: we do not sell personal data. Some state laws treat the use of identifiers for advertising as “sharing”; you can opt out by writing to soporte@nivelcien.lat, and we honor the Global Privacy Control signal. Consumer health data (Washington, Nevada and other states): we collect it only with your consent, for the features described in section 5; we never sell it or share it without separate consent.
16. Changes to this Policy
We will publish each version with its date. If a change is significant, we will ask you to accept it in the app before continuing.
