Privacy policy

IMPORTANT INFORMATION

We may automatically collect language settings, IP address, time zone, type and model of your device, device settings, operating system, Internet Service provider, mobile carrier, hardware ID, and other identifiers from your device. We need this data to provide Services, analyze how our customers use Services, and serve advertising.

To improve Services and serve advertising, we may share this data with third parties, including Shopify, Meta, TikTok, Google, Apple, Microsoft, Klaviyo, Triple Whale and Visually.io. We share this data with third parties to (1) analyze how users interact with Services (e.g., how often users purchase products,) and (2) serve and show advertising only to a particular group of users (e.g., to subscribers). Read this Policy to get more information about what data we collect (Section 2), how we use it (Section 3), with whom we share it (Section 4), and what data privacy rights are available to you (Section 5).

If you are a US resident, check our Privacy Notice for U.S. Residents.

PRIVACY POLICY

This Privacy Policy explains how we (“Company”, “we”) collect, use, store, and share your personal data when you use our website and related services (collectively, the “Services”).

BY USING THE SERVICES, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND, AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE AT LEAST 18 YEARS OLD (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Services. In such case, you must (a) delete your account and personal data using the account settings and (b) cancel any orders or subscriptions you have using the account settings.

Any translation from the English version is provided only for transparency and your convenience. If there is any difference in meaning or interpretation between the English language version of this Privacy Policy and any translation, the English language version will prevail. The original English text shall be the sole legally binding version.

TABLE OF CONTENTS

  1. PERSONAL DATA CONTROLLER
  2. CATEGORIES OF PERSONAL DATA WE COLLECT
    1. Data you directly provide to us
    2. Data we collect automatically
  3. PURPOSES AND LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA
  4. HOW WE SHARE YOUR PERSONAL DATA
  5. YOUR PRIVACY RIGHTS
  6. AGE LIMITATION
  7. INTERNATIONAL DATA TRANSFERS
  8. DATA RETENTION
  9. PRIVACY NOTICE FOR U.S. RESIDENTS
    1. Applicability
    2. Categories of Personal Information We Collect
    3. Purposes of Processing Personal Information
    4. Categories of Personal Information We Disclose and Share with Third Parties
    5. Your Rights
    6. Third-Party Tracking

10. SECURITY MEASURES

11. THIRD-PARTY WEBSITES AND APPLICATIONS

12. CHANGES TO THIS PRIVACY POLICY

13. СONTACT US

1. PERSONAL DATA CONTROLLER

GM Unicorn Corporation Limited (with registered office at 46 Lykavitou, Egkomi, 2401, Nicosia, Cyprus) is the controller of your personal data in most circumstances.

2. CATEGORIES OF PERSONAL DATA WE COLLECT

We collect the following data about you:

  1. Data you directly provide to us (for example, shipping details).
  2. Data we collect automatically when you use the Services (for example, your IP address).

2.1.Data you directly provide to us

Identifiers. This may include your name, phone number, and email address. You provide us with this information when you purchase the products, subscribe to our newsletters or other communications, or contact us by any other means.

Order data. This includes billing and shipping addresses, and details about your order, including discounts and delivery method.

Communications data. When you interact with our support team, we process the contents of your conversations, including your inquiries, feedback, images, or other information you include in such communications. We also process the personal data and the information you send us when you submit requests through any contact, request, or feedback form available within the Services. 

Payment data. When you purchase products and make payments, you provide financial account data, for example your credit card number, to our third-party service providers acting as our payment processors. All order payments are processed by Shopify Payments or your selected payment provider; we do not collect, store, or have access to the full card details you provide to payment processors, including your full credit card number, though we may receive some limited information, such as credit card-related data (including card type, last four digits , payment status, and a secure token reflecting your payment method), data about products purchased, date, time and amount of the purchase, and the type of payment method you used.

2.2.Data we collect automatically

Advertising performance data. We collect data about your referring application or URL (the application or place on the Web you were on when you tapped on our advertising). This may include user ID number, name and type of the advertising campaign, name and ID number of the advertising, and advertising click time.

Device and Location data. We collect data from your mobile device. This may include device ID number, language settings, user ID number, IP address, time zone, type and model of a device, device settings, operating system, screen resolution, Internet Service provider, mobile carrier, hardware ID, and Facebook ID. Also, if your device settings allow us to do so, we may collect your location data when you visit our websites, including such parameters as city, region, country, postal code, and designated market area.

Online activity data. We record how you interact with our Services. For example, we log what features and content you interact with, how often you use the Services, how long you stay in the Services, what sections you use, your orders, whether you view communications we send you, and other.

Advertising IDs. Depending on the operating system of your device, we collect your Apple Identifier for Advertising (“IDFA”), Apple Identifier for Vendors (“IDFV”), or Google Advertising Identifier (“GAID”). You can typically reset these numbers through the settings of your device’s operating system; we do not control these settings or the reset process.

Information from Shopify. If you choose to sign in with Shopify’s “Shop” login, Shopify provides us with your Shop account identifier and verified email address. If your account settings permit that, Shopify may also provide us with your name and saved address and phone number for faster checkout and account setup. You can manage your preferences and access settings in the Shop app or at Shopify website. For more information on Shopify’s data processing practices, please check Shopify’s Privacy Policy.

Cookies and similar tracking technologies. We employ technologies (cookies, SDKs, etc.) to process your data to enhance your user experience, optimize ads, and analyze traffic. For example, we use proprietary cookies necessary to operate the Services: they enable page loading, session management, security and fraud prevention, remember your preferences, and support evaluation of user interactions with new features. They collect limited information about your use of the Services, such as page requests, load times, error logs, etc., for operational and diagnostic purposes. We also use Meta Pixel, TikTok Pixel, and Google tracking technologies to collect data about your actions while using the Services, including what pages you visit, the time you spend on each page, and the actions you take. This data is used to measure the effectiveness of our advertising campaigns and to personalize the content and advertising we show to customers. Unless the applicable laws permit otherwise, we activate these technologies upon your consent when you interact with the Services, visit our websites, use the App, or enable certain features of the Services. Disabling these technologies may affect the functionality of certain features, although the Services will remain usable. Furthermore, we and our partners utilize targeting technologies to tailor advertising, potentially displaying them to you at relevant moments. When enabled, your interactions with the Services or the App could result in seeing our advertising on social media platforms, assisting us in measuring advertising campaign effectiveness.

2.3.Aggregated and de-Identified data

We may aggregate, anonymize, or de-identify your personal data to ensure it cannot reasonably be used to identify you individually. This processed data may be used for statistical analysis and trend identification, to improve our Services, develop new features, or other lawful purposes. For example, we may analyse aggregated online activity, payment, and advertising performance data to identify common interest patterns among customers, which helps us enhance our Services and contribute to their overall quality. Such aggregated data no longer constitutes personal information under applicable privacy laws.

3. PURPOSES AND LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA

We collect and use your data primarily to (1) provide and improve our Services, (2) enhance overall quality of Services, and (3) attract new customers to our Services. Below is a detailed explanation of the legal bases for and purposes of processing your personal data.

Legal bases for and purposes of processing

Purpose of processing

Category of personal data

Lawful basis

To provide Services (e.g., provide content for you) and administer your account

All categories, including the Onboarding and product data and the palm/face image

Performance of a contract with you

To process your orders

Identifiers

Order data

Payment data

Device and Location data

Performance of a contract with you

To research, analyze, and enhance performance of the Services

Identifiers

Order data

Payment data

Advertising performance data

Device and Location data

Online activity data

Advertising IDs

Cookies and similar tracking technologies

Legitimate interest (check the description)

To provide customer support

Identifiers

Order data

Communications data

Payment data

Advertising performance data

Device and Location data

Online activity data

Cookies and similar tracking technologies

Your consent

Performance of a contract with you (when we fulfil contractual terms)

To process payments, refunds, and chargebacks

Identifiers

Order data

Payments data

Device and Location data

Online activity data

Performance of a contract with you (when we fulfil contractual terms)

Legal obligation (if we take action as required by the law)

Your consent

Legitimate interest (check the description)

To enforce Terms of Use, investigate complaints from users and advisors (psychics), prevent and combat fraud, violations of law and misbehavior, and ensure informational security of the Services

Identifiers

Order data

Communications data

Payment data

Information from Shopify

Device and Location data

Online activity data

Cookies and similar tracking technologies

Legal obligation (when we take action as required by the law)

Legitimate interest (check the description)

To send communications about the Services

Identifiers

Order data

Payment data

Advertising performance data

Device and Location data

Online activity data

Cookies and similar tracking technologies


Performance of a contract with you

To send marketing communications

Identifiers

Order data

Payment data

Device and Location data

Online activity data

Cookies and similar tracking technologies


Your consent

Legitimate interest (check the description)

To serve personalized advertising

Identifiers

Order data

Payment data

Advertising performance data

Device and Location data

Online activity data

Advertising IDs

Cookies and tracking technologies

Your consent

Legitimate interest (check the description)

To analyze performance of advertising


This includes measuring impression accuracy, ensuring proper ad placement and quality, and confirming compliance with industry standards

Identifiers

Order data

Payment data

Advertising performance data

Device and Location data

Online activity data

Advertising IDs

Cookies and tracking technologies

Your consent


Legitimate interest (check the description)

To comply with legal obligations

All categories

Legal obligation

Description of our legitimate interests

When researching, analyzing, and enhancing performance of the Services: to improve the Services by better understanding of users’ preferences, being able to provide a better user experience, making the use of the Services easier and more enjoyable, or introducing new features, offers, and products.

When processing payments, refunds, and chargebacks: to protect our business from fraudulent claims; to make informed and efficient decisions regarding refund requests.

When enforcing Terms of Use, preventing and combating fraud violations of law, and misbehavior, and ensuring informational security of the Services: to enforce our legal rights, policies, and rules; to prevent and address fraud, violations of law, misbehaviour, and unauthorized use of the Services; to prevent attacks on and unauthorised access to the Services; to ensure compliance with our Terms of Use. This helps provide a secure and reliable Services for all users.

When sending marketing communications: in jurisdictions where consent is not required, our legitimate interest is to encourage you to use and promote the Services, for example, if you didn’t purchased the Services, we may send you reminders emails inviting you to complete a purchase.

When serving personalized advertising: in jurisdictions where consent is not required, our legitimate interest is to promote the Services in a measured and reasonably targeted way, showing you content that's more likely to be relevant to your interests rather than generic advertising.

When analyzing performance of advertising: in jurisdictions where consent is not required, our legitimate interest is to promote the Services in a measured and appropriate way and to ensure the accuracy and quality of our advertising campaigns and complying with industry standards. This helps us measure effectiveness and maintain transparent business practices.

4. HOW WE SHARE YOUR PERSONAL DATA

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Services. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 3 of this Policy. We strive to conclude specific data processing agreements with all such parties to establish the rules for processing of your data specifically on our behalf and limited to it.

The types of third parties we share information with include the following:

Third-party providers. We share personal data with third parties that we engage to provide services or perform business functions on our behalf, based on our instructions. We process your personal information using the following types of service providers (and in certain cases, their subprocessors):

a. Shopify: We use Shopify to power our online store.

b. Data analytics:

  • We use Microsoft Clarity to record how you use and interact with the Services; this might include session recordings.
  • We use Visually.io to run A/B tests, evaluate feature performance, and improve the Services by analysing feature experiment results and user interactions with the Services.
  • We use Meta Pixel and Google Analytics to analyze how you use the Services and measure the effectiveness of some advertising.
  • We use Triple Whale to create interactive dashboards, charts, reports, and visualise data about your use and interaction with the Services.

c. Gateway service and payment processing: We use various payment processing and payment gateway providers that help us connect with different banks and payment systems around the world. Due to the large number of payment processing providers we work with, we cannot list them all here.

d. Communications:

  • We use Klaviyo to send service-related and marketing communications to you.

e. Technical, administrative, and information service providers: From time to time, we may use various third-party tools to ensure project and task management, launch feedback forms and surveys, enable communication, collaboration and productivity across our departments, or automate workflow. In some cases, limited personal data may be shared with these service providers. Examples of such tools include Google Workspace, Slack, Notion, and Atlassian Jira.

f. Advisors, consultants, and independent contractors. From time to time, we may share limited personal information with our independent contractors, consultants, third-party specialists, partners, and advisors. They process this information on our behalf to operate, maintain, secure, and improve the Services, and ensure legal and regulatory compliance. We require them to use the information only for these purposes, protect it appropriately, and keep it confidential.

g. Marketing and advertising:

  • We use Meta Ads Manager and Meta Custom Audience, and TikTok Ads Manager to choose audiences that will see our advertising and deliver advertising on Meta’s and TikTok’s platforms.
  • We use Google Ads to deliver advertising to users in Google browsers.
  • From time to time, we may use third-party ad networks, ad agencies, and direct publishers that provide us with advertising solutions for displaying our advertising on various websites and apps.

Law enforcement agencies and other public authorities. We may use and disclose personal data to enforce our Terms of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

Third parties as part of a merger or acquisition. As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Affiliates. We may share your personal information with our partner organizations that are part of our corporate group. These are the companies that are owned by, own, or are jointly-owned with us. These partner organizations will use the information in ways that align with this Policy, ensuring that your privacy is respected and protected across all our affiliated services.

5. YOUR PRIVACY RIGHTS

We encourage you to contact us first regarding any issues related to your personal data processing. Feel free to contact us using this request form.

To be in control of your personal data, you have the rights specified below. Depending on where you reside, the applicable laws may not grant you some of these rights or they may be named differently. If you are a US resident, check our Privacy Notice for U.S. Residents.

Your Rights

How to Exercise Them

Right to Access / Know

An individual’s right to receive information about what personal data we process, how we use it, and with whom we share it

We provide this information throughout this Privacy Policy, including what categories of personal data we process (Section 2), the purposes of and the legal bases for the processing, (Section 3), and with whom we share personal data (Section 4).

We encourage you to check this Policy to find the information you are interested in.

Right to Delete / Erase

An individual’s right to request the deletion of their personal data, except when the data deletion is limited under the applicable laws

You can delete your personal data using “Delete Account” functionality in your account settings. Otherwise, you can send a data deletion request via this request form.

When you request to erase your personal data, we will use reasonable efforts to honor your request. In some cases we may be legally required to keep some of the data for a certain time as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements; in such event, we will fulfill your request after we have complied with our obligations.

Right to Rectify / Correct

An individual’s right to request the correction of inaccurate personal data about that individual

You can easily correct (rectify) your personal data in the account settings of your account settings.

Some information may not be available for updating in the account settings. This information is collected automatically on the system level and cannot be manually rectified due to its nature. Instead, it updates in real-time every time you use the Services. This approach is aimed to ensure integrity and confidentiality of your personal data and reflects the best practices recommended by the applicable laws.

Right to Withdraw / Revoke Consent

When the processing of individual’s personal data is based on their consent, an individual’s right to withdraw consent to the processing of personal data they earlier provided

Only a limited number of processing activities is based on your consent; see Section 3 for details.

To withdraw consent to the processing of your personal data for personalised advertising, use the Preference Center menu.

To revoke consent to the processing of your personal data for sending marketing communications, use the “Unsubscribe” link available in the email or submit your request using this request form.

Right to Access a Copy / Port

An individual’s right to request data controller to send them a copy of their personal data

You can submit a request to send you a copy of your personal data using this request form.

Other

You can submit other requests regarding the processing of your personal data using this request form.

We may be required to verify your identity before being able to process your request. The verification process may include confirming your name, age, email address, date of subscription purchase, date of account creation, or other relevant Services usage data that reasonably identify you as the account owner. We may also request additional proof of identity if necessary, but we strive to minimize the information required. For certain requests, we may send a verification code or ask you to sign a declaration under penalty of perjury to authenticate your identity.

If you designate an authorized agent to exercise your rights on your behalf, they will need to provide the necessary verification information to confirm their identity and authorization.

6. AGE LIMITATION

We do not knowingly allow anyone under 18 to use the Services, and we do not knowingly collect or process personal data from anyone under 18. If you learn that anyone younger than 18 has used the Services or provided us with personal data, please contact us using this request form.

7. INTERNATIONAL DATA TRANSFERS

We may transfer personal data to countries other than the country in which the data was originally collected (1) to provide the Services set forth in the Terms of Use and (2) to achieve purposes indicated in this Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we employ appropriate safeguards.

8. DATA RETENTION

We retain your personal data for as long as necessary to fulfill the purposes described in this Privacy Policy and the Terms of Use, including to provide Services to you. When determining the appropriate retention period, we consider the volume, nature, and sensitivity of the personal data; the data’s relevance to performing the contract and providing the Services (including the possibility of re-enrollment); the potential risk of harm from unauthorized use or disclosure; the purposes for which we process your personal data and whether those purposes can be achieved by other means; and applicable legal requirements, including mandatory retention periods, statutes of limitation, legal holds, and litigation requirements.

As a general rule, we keep your personal data for as long as you maintain a registered account or certain personal information with us. However, retention period may be shorter or longer depending on the lawful basis for processing (see Section 3 for more information):

  • When we process data on a basis of consent: until you withdraw your consent.
  • When we process data to perform a contract: for the duration of the contract.
  • When we process data to pursue our legitimate interest: for the time needed to achieve the stated interest, considering necessity and impact on your privacy.
  • When we process data to comply with legal obligation: until we fulfill the legal obligation imposed on us by the applicable laws.

If multiple lawful bases apply, we keep the personal data until the latest applicable period expires. In any of the above situations, if you decide to delete your account, we delete or anonymise the related personal data unless retention is required to comply with our legal obligations, establish, exercise, or defend legal claims, resolve disputes, and enforce our agreements. For example, certain accounting and tax laws require us to store Payment Data for long periods of time to comply with laws we are subject to. Therefore, even if you submit a data deletion request, a small portion of the data that relates to our compliance obligations will be stored even after the request is satisfied.

9. PRIVACY NOTICE FOR U.S. RESIDENTS

9.1.Applicability

This Privacy Notice for U.S. Residents (“Notice”) supplements our Privacy Policy and provides disclosures required by laws in the U.S. states that have enacted consumer privacy laws. If you reside in one of these states, this section applies to you. For California residents, this also serves as our California Notice at Collection.

The scope of “Personal Information” may vary by state law. Generally, it refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

9.2.Categories of Personal Information We Collect

Section 2 of our Privacy Policy specifies the categories of Personal Information we collect and the categories of sources from which we collect Personal Information.

9.3.Purposes of Processing Personal Information

For each category of Personal Information, Section 3 of our Privacy Policy describes the intended purposes of collecting, processing, and sharing Personal Information, including for targeted advertising.

9.4.Categories of Personal Information We Disclose and Share with Third Parties

For additional details regarding the third parties with whom we share Personal Information and the purposes for that sharing, please see Section 4 of this Privacy Policy.

Please note: we do not disclose Personal Information to any third parties for their direct marketing purposes. To our reasonable knowledge, no third party to whom we disclose Personal Information uses it for their own direct marketing purposes.

Please note: from time to time, we may engage technical, administrative, and information service providers, advisors, consultants, and independent contractors  and may disclose to them any categories of Personal Information specified below for business purposes as necessary to operate and support the Services. When we do so, we disclose only the minimum information required for these purposes and apply appropriate security and confidentiality measures.

We disclose the following Personal Information for business purposes, to ensure operation of our business, as specified below:

Enumerated Category of Personal Information under Cal. Civ. Code Section 1798.140(v)

Third Parties to Whom We Disclose Personal Information

Identifiers
(Account name, unique personal identifier, online identifier, IP address, email address).

  1. Shopify
  2. Data analytics tools 
  3. Payment processing and gateway service providers 
  4. Customer support and communications service providers 
  5. Service providers of marketing and advertising tools 

Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)
(Name, address, telephone number, bank account number, credit card number, debit card number, or any other financial information).

Commercial information
(Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

  1. Shopify
  2. Data analytics tools 
  3. Payment processing and gateway service providers 
  4. Customer support and communications service providers
  5. Service providers of marketing and advertising tools

Internet or other electronic network activity information
(Browsing history, search history, information regarding a consumer’s interaction with an internet website application, or advertisement)

  1. Data analytics tools 
  2. Shopify
  3. Service providers of marketing and advertising tools

Geolocation data

(Approximate geolocation only)

  1. Shopify
  2. Data analytics tools
  3. Service providers of marketing and advertising tools

Sensitive personal information
(Contents of communication, account access information)

  1. Shopify
  2. Customer support and communications service providers

Inferences Drawn from Personal Information
(Consumer profiles reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes)

We do not collect or process this information

Characteristics of Protected Classifications under California or Federal Law
(Age (over 40), sex, including gender)

Biometric information

Sensory Information

(Audio, electronic, visual, thermal, olfactory, or similar information)

Professional or employment-related information

Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)
(Records that are directly related to a student and maintained by an educational agency or institution, or by a party acting for the agency or institution)

We do not sell or otherwise monetize Personal Information, except for sharing it for cross-context behavioral advertising as described below:

Enumerated Category of Personal Information under Cal. Civ. Code Section 1798.140(v)

Third Parties with Whom We Share Personal Information

Identifiers
(Account name, unique personal identifier, online identifier, IP address, email address).

  1. Service providers of marketing and advertising tools
  2. Third-party ad networks, ad agencies, and direct advertising publishers

Commercial information
(Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

Internet or other electronic network activity information
(Browsing history, search history, information regarding a consumer’s interaction with an internet website application, or advertisement)

Geolocation data

(Approximate geolocation only)

Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)
(Name, address, telephone number, bank account number, credit card number, debit card number, or any other financial information).

We do not share this information for cross-context behavioral advertising

Sensitive personal information
(Contents of communication, account access information)

Characteristics of Protected Classifications under California or Federal Law
(Age (over 40), sex, including gender)

We do not collect or process this information

Inferences Drawn from Personal Information
(Consumer profiles reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes)

Biometric Information

Sensory Information

(Audio, electronic, visual, thermal, olfactory, or similar information)

Professional or employment-related information

Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)
(Records that are directly related to a student and maintained by an educational agency or institution, or by a party acting for the agency or institution)

 

9.5. Your Rights

Certain U.S. state consumer privacy laws provide you with specific rights regarding your Personal Information. Beyond the rights described in Section 5 of Privacy Policy, you may have the following rights depending on the U.S. state you reside in:

  • Right to Opt-Out of Sale, Sharing, and Targeted Advertising. You may opt out of certain uses of your personal information, including “sharing” of your Personal Information as defined under state consumer privacy laws and the use of your Personal Information for targeted advertising. To exercise this right, use the Do Not Sell or Share My Personal Information menu. We also recognize and honor browser- or device-based opt-out preference signals such as the Global Privacy Control (GPC). For California residents, this also serves as our California Notice of Right to Opt-out of Sale or Sharing.
  • Right to Appeal. If we deny your request to exercise any of your rights, you may have the right to appeal our decision. To do so, please contact us via a dedicated request form and explain your concerns.

You can exercise your rights as described in Section 5 of this Policy. Alternatively, you can submit your request via this request form.

We do not discriminate or retaliate against users because they exercise their privacy rights.

9.6. Third-Party Tracking

When you use the Services, including communications with our advisors (psychics), certain aspects of your interactions may be recorded, monitored, or analyzed in accordance with our Terms of Use and this Policy. This may include recording or analyzing your personal data for the purposes of service delivery, research and improvement, quality assurance, and third-party advertising.

Where required under applicable law, we provide you with notice of such processing and obtain your consent prior to or at the point of collection. By accessing or using our Services, you further acknowledge and consent to such recording, monitoring, and analysis of your communications to the extent permitted by applicable law. To the extent required by applicable law, we hereby notify you that your interactions with our Services may be subject to monitoring, recording, or analysis for the purposes described in this Policy and our Terms of Use, and your continued use of our Services constitutes your explicit consent thereto.

If you do not consent to the processing practices described above, please discontinue use of our Services.

10. SECURITY MEASURES

We use reasonable and appropriate organisational, technical, administrative, and physical security measures as required by the applicable laws to protect your personal data from unauthorized access, disclosure, use, and modification. This includes without limitation pseudonymisation and encryption of personal data, access management, vulnerability testing, user authorisation procedures, organisational policies, and regular tests and assessments of technical and organisational measures. We regularly review our security procedures and policies to consider appropriate new technology and methods. However, the Internet is not 100% secure and we cannot promise that your use of the Services of the App will be completely secure. We encourage you to use caution when using the Internet, including not sharing your passwords to our Services.

11. THIRD-PARTY WEBSITES AND APPLICATIONS

The Services may contain links to other websites or applications and other websites or applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

12. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, we will notify you through our Services or by other available means and will provide you with an opportunity to review the revised Privacy Policy. By continuing to access or use the Services or the App after those changes become effective, you agree to be bound by the revised Privacy Policy.

13. CONTACT US

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us using this request form.

You can also contact our data protection officer regarding any privacy‑ or data‑protection‑related matter using the dedicated contact form.

Effective as of: 13 August 2026