1. Introduction
Welcome to Oraclium. We are committed to protecting your personal data and upholding your privacy rights in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR), Federal Data Protection Act (BDSG), and the Telecommunications-Telemedia Data Protection Act (TTDSG).
This Privacy Policy explains what data we collect, how we process it, and the rights you have as a user of our mobile app and related web services.
2. Data Controller
Company Name: [Insert your official company name]
Legal Representative: [Insert full name]
Address: [Insert street, city, postal code, country]
Email for privacy inquiries: [yourprivacy@yourdomain.com]
We are established in Germany and operate under the applicable German and EU privacy laws.
3. What Personal Data We Collect
We may collect and process the following categories of data:
a. Profile and Identity Data
- Username, email (if registration is required)
- Gender identity and name (if provided voluntarily)
b. Astrological and Emotional Data
- Date, time, and place of birth
- Mood entries and emotional states (self-assessed)
- Selected preferences for daily insights (love, wealth, intuition, etc.)
c. Device and Technical Data
- IP address
- Device type, OS version, language settings
- Advertising identifiers (IDFA/GAID)
- App usage logs, crash reports, feature engagement
d. Payment and Transaction Data
- Purchase and subscription history
- Payment tokens or Stripe session identifiers (Note: we do not store credit card information directly)
4. How We Use Your Data
We use your data for the following purposes:
- Deliver personalized horoscopes and astrology reports
- Analyze mood trends and generate reflective insights
- Process in-app purchases and manage credits
- Improve app functionality through diagnostics and crash reporting
- Serve relevant, interest-based advertisements
- Communicate updates, offers, or account-related notifications
5. Legal Basis for Processing (GDPR Art. 6)
| Purpose | Legal Basis |
|---|---|
| Astrological and mood features | Consent (Art. 6(1)(a)) |
| Purchase fulfillment | Contract (Art. 6(1)(b)) |
| Analytics and crash reports | Legitimate interest (Art. 6(1)(f)) |
| Advertising and tracking | Consent (Art. 6(1)(a)), TTDSG §25 |
| Legal compliance (tax, fraud) | Legal obligation (Art. 6(1)(c)) |
You can withdraw your consent at any time within the app settings or by contacting us.
6. Consent and User Controls
- We present clear consent screens before collecting sensitive data (e.g., date of birth, mood input).
- You can change or withdraw your consent at any time via your profile or settings.
- Ad tracking and analytics are disabled by default until consent is given (especially under TTDSG).
7. Cookies and Tracking (Web + Mobile)
For our web landing page, we use cookies and consent banners compliant with TTDSG.
In our mobile app, we use SDK-based tracking tools:
- Firebase Analytics
- Google AdMob / Ad Manager
- AppLovin MAX
- Adjust (if used)
You may opt-out of ad tracking via your device settings.
8. Third-Party Data Processors
We share personal data with the following processors under strict data protection agreements:
| Provider | Purpose | Location of Servers |
|---|---|---|
| Firebase | Analytics, Crash Reports | EU/USA |
| Stripe | Payment Processing | EU/USA |
| AdMob/Ad Manager | Advertising Delivery | EU/USA |
| AppLovin MAX | Ad Mediation | EU/USA |
We use Standard Contractual Clauses (SCCs) where data is transferred to third countries (e.g., USA).
9. Data Retention
We retain your data only as long as necessary:
- Astrology and profile data: Until you delete your account
- Mood entries: 12 months or upon user deletion
- Crash/analytics data: 14 months
- Payment data: 10 years (legal requirement in Germany)
10. Your Rights (GDPR Articles 15–22)
You have the right to:
- Access your personal data
- Rectify inaccurate or incomplete data
- Request deletion of your data
- Restrict or object to certain processing
- Port your data to another provider
- Withdraw consent at any time
- File a complaint with the German Data Protection Authority (BfDI)
To exercise any of these rights, contact: [yourprivacy@yourdomain.com]
11. Children’s Privacy
Our services are not intended for users under the age of 16. We do not knowingly collect personal data from minors.
12. International Data Transfers
Some of our processors are located outside the EU. In such cases, we use GDPR-approved safeguards including:
- Standard Contractual Clauses (SCCs)
- Vendor security certifications and audits
- Encrypted communications and data minimization
13. Data Security
We implement strong technical and organizational measures including:
- End-to-end encryption of sensitive data
- Secure HTTPS API communication
- Access controls and audit logs
- Regular security updates and vendor assessments
However, no method of transmission is 100% secure.
14. Changes to This Policy
We may update this policy from time to time. Users will be notified via app notifications or email. You can always view the latest version in the app settings or on our website.
15. Contact
For questions or privacy-related requests, contact:
[Company Name]
[Address]
Email: [yourprivacy@yourdomain.com]