Privacy Policy

Last updated 2026-10-23.

Draft text. This document is a working draft for the demo installation. It must be completed and reviewed by a qualified lawyer before the service goes live.

The controller of your personal data is Centhead. Privacy contact: privacy@example.com.

What we collect and why

DataPurposeLegal basis (GDPR)
Email, display name, password hash (scrypt), countryYour account, sign-in, taxes and legal requirementsContract (Art. 6(1)(b)); legal obligation
Age confirmation and terms acceptance, with timestampsProof of eligibility and consentLegal obligation; legitimate interest
Ad views, offers, earnings, withdrawals, referral relationshipsPaying you, accounting, tax, fraud preventionContract; legal obligation
Two-step verification secret (encrypted) and recovery code hashesProtecting your accountLegitimate interest; contract
Session records: browser description, a keyed hash of your IP address, activity timesSecurity, session management, fraud and multi-account prevention. We do not store raw IP addresses.Legitimate interest (Art. 6(1)(f))
Payout account reference and verification statusWithdrawals and anti-money-laundering. Identity documents, bank and tax details are held by Stripe, not by us.Legal obligation; contract
A pseudonymous id supplied by an app that embeds CentheadCrediting earnings to the right personContract
Anonymous member id sent to offer and survey networksSo the network can report completions to us. We send no email or name.Contract

What we do not do

We do not sell personal data, build advertising profiles of you or use tracking cookies. Ad and offer networks that serve content inside Centhead process data under their own policies, which we link from the relevant screens.

Processors and recipients

Stripe (payouts, identity verification), our hosting provider, our email provider, Cloudflare (bot protection on presence checks) and the advertising and offer networks you choose to interact with. Where data leaves the European Economic Area we rely on adequacy decisions or Standard Contractual Clauses.

Retention

Account data is kept while your account is active. Ledger records are kept, de-identified after account deletion, for as long as accounting law requires. Security logs and flags are kept for up to 24 months.

Your rights

You can access and download your data (Settings, “Download my data”), correct it, delete your account (Settings, “Delete my account”; we keep only de-identified records we are legally required to keep), restrict or object to processing, and complain to your data protection authority. Write to privacy@example.com for anything else; we answer within one month.

Security

Passwords are hashed with scrypt, sensitive secrets are encrypted at rest, connections use TLS, access is logged, and the money ledger is append-only. See the Security page.

Children

Centhead is for adults. We do not knowingly collect data from anyone under 18 and delete accounts we learn belong to a minor.