PRIVACY POLICY

EMPIRE SOVEREIGN SYSTEMS

Last Updated: February 4, 2026

1. INTRODUCTION

Empire Sovereign Systems ("we," "our," or "us") operates the CENTURION mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App.

By using CENTURION, you agree to the collection and use of information in accordance with this policy.

2. INFORMATION WE COLLECT

2.1 Information You Provide

2.2 Automatically Collected Information

2.3 Health & Biometric Data

CENTURION may display simulated biometric data (HRV, sleep, recovery scores) for motivational purposes. If you choose to connect Apple Health:

3. HOW WE USE YOUR INFORMATION

We use collected information to:

4. DATA STORAGE & SECURITY

4.1 Local Storage

4.2 Cloud Services

4.3 Security Measures

We implement industry-standard security measures including:

5. THIRD-PARTY SERVICES

ServicePurposePrivacy Policy
RevenueCatSubscription managementrevenuecat.com/privacy
Apple App StoreApp distribution & paymentsapple.com/privacy
ExpoApp frameworkexpo.dev/privacy

6. YOUR RIGHTS

6.1 Access & Portability

You have the right to:

6.2 Deletion

You can delete your data by:

6.3 Opt-Out

You may opt out of:

7. CHILDREN'S PRIVACY

CENTURION is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us.

8. INTERNATIONAL DATA TRANSFERS

If you access CENTURION from outside the United States, your information may be transferred to, stored, and processed in the United States where our servers are located. By using the App, you consent to such transfer.

9. CALIFORNIA PRIVACY RIGHTS (CCPA)

California residents have additional rights:

10. EUROPEAN PRIVACY RIGHTS (GDPR)

If you are in the European Economic Area, you have rights under GDPR including:

Legal Basis for Processing: We process your data based on contract performance, legitimate interests, and your consent (where applicable).

11. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy in the App, updating the "Last Updated" date above, and sending a push notification for material changes.

12. CONTACT US

If you have questions about this Privacy Policy, please contact us:

Empire Sovereign Systems
Email: 23adamkaminski@gmail.com
Subject Line: "Privacy Policy Inquiry"