This notice sets out the basis on which we collect any personal data relating to you, or that you provide to us in relation to us providing astrology, palmistry, numerology, horoscope and biorhythm services. Who are we?
"We", "our" or "us" means Astro Code OU. Our company number is 14780616. Our registered office is at Sepapaja tn 6, Tallinn 15551, Estonia.
We are the controller of your personal data. This means that we are responsible for deciding how we collect, store and use your personal data.
If you have any questions about this privacy notice, please contact our User Relations Manager at email@example.com. Who does this privacy notice apply to?
This privacy notice applies to all users of our app "AstroCode". It does not form part of our contract to provide services.
We may update this privacy notice at any time. This privacy notice answers the following questions:
- What personal information do we collect?
- Why do we use your personal data and our lawful basis?
- What happens if you don't provide the personal data we have asked for?
- Will we use your personal data for automated decision-making and profiling?
- Can we change the purpose for which we use your personal data?
- How long do we keep your personal data for?
- Do we share your personal data with any third parties?
- Sharing your personal data for advertising purposes
- How do we keep your personal data secure?
- What rights do you have over your personal data?
- How will we tell you about changes to this privacy notice?
- How to contact us
What personal data do we collect?
- Information you give us when registering with our app: We will require you to provide us with the following personal data when you register with our app:
- Date of birth
- Time of birth
- Place of birth
- Other information you provide to us: If you lodge a customer query your email address and any other information about yourself you choose to provide to use us when you lodge a customer query with us. If you engage with any chat functionality then you may provide us with personal data via this function.
- Information we collect about you: We will collect a non-personally identifying unique identifier from Apple in order to link your use of the app for billing through iTunes and for advertising purposes.
- Information collected by third parties: Information is collected by third party SDKs on the app and our website providers. They will collect the following data related to your usage: your IP address, cookies, unique device identifiers, URL, and the sequence of pages visited. We do not collect this information ourselves and it is collected by the relevant third parties. This information is only shared so as to allow the app to operate. To see how they use this information please refer to their privacy policies. We have provided links to these. If you do not want to share this information you should adjust your device privacy settings to "do not track". We have set out how to do that below.
Why do we use your personal data and our lawful basis?
- Analytics & Tracking providers
In accordance with the DPA and GDPR, we will only process your personal data where we have a lawful basis for doing so. In respect of your personal data, these bases are: (i) where it is necessary to provide services to you under the performance of the contract we have with you; (ii) where we are required to do so in accordance with legal or regulatory obligations; (iii) where you have given your consent; and, (iv) where it is in our legitimate interests to process your personal data, provided that none of these prejudice your own rights, freedoms and interests.
The following are a list of the "Purposes" for which we (including any of our agents, processors, and/or employees) process your personal data and the lawful basis on which we carry out such processing: Purpose Lawful Basis
To provide services related to astrology to you Necessary for the performance of a contract To set-up, administer and manage your account Necessary for the performance of a contract To confirm your valid subscription to our app Necessary for the performance of a contract To receive and respond to your communications and requests Necessary for the performance of a contract where such communication relates specifically to our Services, otherwise legitimate interests so that we can respond to your query To notify you about updates to our app and services, including updates to this privacy notice and any terms we have with you Necessary for the performance of a contract To access information from your Facebook profile and make this visible to your Facebook on our app Consent To carry out market research campaigns Legitimate interests so that we can better understand the products and services that our customers most enjoy To prepare statistics relating to the use of our app by you and other customers Legitimate interests so we can understand the use of, and therefore improve, our app and services To keep you informed of offers and promotions relating to our services Legitimate interests where the offers relate to similar or identical goods and services to those you subscribe to and we have offered you an option to opt-o. Consent for any other type of marketing and we will offer an option to opt-in. To record communications with our customer services representatives for training purposes Legitimate interests so that we improve our customer services To use your name, image, username or location in publicity and marketing, but only where you have provided your express and informed consent for us to do so Consent Where we allow third parties to collect and use your personal data in respect of analytics and advertising, we will only do so if permitted in your device system settings. You can change this setting as detailed above. What happens if you don't provide the personal data we have asked for?
Where we have stated that your personal data is used in order to carry out a contract with you, to take steps to enter into that contract we will need you to provide the personal data requested. If you don't provide that personal data when we ask for it, we may not be able to respond to you, enter into a contract with you or meet our obligations to you under that contract. For example, if you don't give us your date of birth we will be unable to create your astrology portrait. If you have any concerns about whether you need to provide your personal data please contact our User Relations Manager at firstname.lastname@example.org. Will we use your personal data for automated decision-making and profiling?
We do not use your personal data to make automated decisions about you. We do use information you enter into the App to generate a general profile about you based on the information you input into the App. However, the content is for entertainment purposes only and should not be used by you as the basis for any important legal or similarly significant decision. Can we change the purpose for which we use your personal data?
We will only use your personal data for the purposes set out above or for a new reason that is compatible with those original purposes. If we change the purpose for which we use your personal data we will update this privacy notice. If you would like an explanation as to how the new purpose is compatible with the original purpose please contact our User Relations Manager at email@example.com.
If we would like to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do this. How long do we keep your personal data for?
We will only keep your personal data for as long as is necessary.
We retain information relating to your contract with us and your use of the app for so long as you use the app. Once you unsubscribe we will retain your personal data for a period of up to six years. Please note that deleting the app will not result in an unsubscribe request.
We retain information relating to support queries for 1 year after we close the relevant support query. Do we share your personal data with any third parties?
We share your personal data with trusted third parties who support our app (such as designing our app infrastructure and customer support service). If we do this, we will put in place a contract with them which requires them to only process your personal data in accordance with our instructions which requires that your personal data is treated in accordance with data protection laws.
We may disclose your personal data in the following circumstances but only where we determine that doing so is permitted under GDPR and DPA:
Sharing your personal data for advertising purposes
- to any law enforcement body which may have any reasonable requirement to access your personal data;
- to any potential purchaser of our business or any investors in it;
- in order to defend ourselves legally; and
- in order to enforce our legal rights.
We do not share information that could identify you personally with our third-party advertising partners (as listed above) for the purposes of advertising, remarketing and behavioural advertising based on your use of the app. We do share information that can help those partners to deliver personalised advertisements to you – this information will not identify you personally. If you would like to prevent this sharing then please change your settings.
How do we keep your personal data secure?
- You can Opt Out on an Apple iOS Device, such as iPhones, iPads or iPods by switching Limit Ad Tracking to "On". For iOS 6.0 devices and higher, this setting can be changed using the following path: Settings, General, Privacy, Advertising and toggling "Limit Ad Tracking" to 'ON'.
- You can Opt Out on an Android Device of interest-based advertising, you may do this as follows: Open the Settings app on your device, Go to "Google", Select Ads, Opt-out of interest-based ads.
We take appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties (see above) who have a business need-to-know.
We have put procedures in place to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where the breach may cause a risk to you.
Our security procedures mean that we may occasionally request proof of identity before we are able to disclose personal data to you. What rights do you have over your personal data?
Data protection laws grant you certain rights in relation to your personal data and our processing. You have the following rights in relation to your personal data:
- a right to request confirmation from us as to whether we are processing your personal data and, if so, a copy of such personal data;
- a right to request that inaccurate personal data is rectified;
- a right to request to receive your personal data in a machine-readable format and to request that we provide this to a third party controller;
- a right to object to processing where the lawful basis is that it is in our legitimate interests, but please note that we may still process your personal data where there are other relevant lawful bases or where we have compelling grounds to continue processing your personal data in our interests which are not overridden by your rights, interests or freedoms;
- a right to request that certain personal data is erased where it is no longer necessary for us to process it, where you have withdrawn your consent (as described immediately below), or where you have objected (as described immediately above), where your personal data has been unlawfully processed, or where erasing your personal data is required in accordance with a legal obligation;
- a right to withdraw your consent where this is the lawful basis on which we process your personal data;
- a right to request an explanation of the logic involved where we make decisions about you solely through automated means;
- a right to complain to your national data protection supervisory authority; and
- a right to object to direct marketing.
If you are unsure about your rights or are concerned about how your personal data may be processed, please feel free to contact our User Relations Manager at firstname.lastname@example.org
If you would like to exercise any of your rights then you can do so by contacting us at email@example.com
. Please be aware that while we will try to accommodate any request you make in respect of your rights, they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.
Where you make a request in respect of your rights we will require proof of identification. We may also ask that you clarify your request. We will aim to respond to any request within one month of verifying your identity. If we receive repeated requests or have reason to believe requests are being made unreasonably, we reserve the right not to respond. Our Policy Toward Children
Our apps are not directed to children under 13 and we do not knowingly collect personal data from children under 13. If we discover that we have collected any personal data about a child under 13, we will take steps to delete it from our systems as soon as possible.
If you are under the age of 18, you must have your parent's permission to download and use our apps. How will we tell you about changes to this privacy notice?
If you have any questions about this privacy notice or about the ways we use your personal data, please contact us at firstname.lastname@example.org