PRIVACY POLICY

1. INTRODUCTION

ASTRO KEY LIMITED LIABILITY COMPANY (“ASTRO KEY LLC”, “AstroKey”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your Personal Data.

This Privacy Policy explains how we collect, use, store, disclose, and otherwise process Personal Data when you use:

• the AstroKey website;
• AstroKey mobile applications;
• AstroKey accounts;
• astrology, numerology, compatibility, birth chart, personalized report and related features;
• paid subscriptions and premium functionality;
• customer support;
• other services operated by AstroKey,

collectively referred to as the “Service”.

This Privacy Policy also explains the privacy rights that may be available to you depending on where you live.

2. DATA CONTROLLER

For purposes of the EU General Data Protection Regulation (“GDPR”) and similar privacy laws, the controller responsible for Personal Data processed through the AstroKey Service is:

ASTRO KEY LIMITED LIABILITY COMPANY

Short name: ASTRO KEY LLC

Identification code: 46242532

Registered office:

23/1 Smilianska Street, Office 7 Cherkasy, Cherkasy Region, 18002 Ukraine

Email:

[email protected]

Website:

astro-key.com

Questions or requests relating to privacy may be submitted to:

[email protected]

3. PERSONAL DATA WE COLLECT

The Personal Data we collect depends on how you use AstroKey.

3.1. Account and Contact Information

When you create or use an AstroKey account, we may collect information such as:

• email address;
• account identifier;
• username or display name;
• authentication information;
• language;
• country or region;
• communication preferences.

If third-party authentication is available, such as Apple or Google sign-in, we may receive information made available by the applicable authentication provider according to your settings and that provider's policies.

3.2. Birth and Astrology Information

To provide personalized astrology, numerology, birth chart, compatibility and related functionality, you may provide information including:

• date of birth;
• time of birth;
• place of birth;
• name or nickname;
• gender or similar profile information where voluntarily provided;
• zodiac, numerology or astrology-related profile information;
• information about another person used for compatibility or similar calculations.

Place of birth information is used to generate requested astrology-related calculations and should not be confused with real-time device location unless the Service expressly asks for permission to access your device location.

3.3. User Content

We may process information you voluntarily enter, upload, submit or otherwise provide through AstroKey.

This may include:

• questions;
• prompts;
• descriptions;
• notes;
• feedback;
• information used to generate personalized reports;
• communications with customer support.

You should avoid submitting unnecessary sensitive information through free-text fields.

3.4. Generated Content and Profile Information

The Service may create personalized information derived from data you provide.

This may include:

• birth charts;
• astrology interpretations;
• numerology calculations;
• compatibility analyses;
• personalized reports;
• generated recommendations or explanations;
• AI-assisted or algorithmically generated content.

Such generated content may be associated with your AstroKey account.

3.5. Subscription and Purchase Information

We may receive information relating to purchases and subscriptions, including:

• subscription plan;
• subscription status;
• transaction identifier;
• purchase date;
• renewal date;
• expiration date;
• trial status;
• currency;
• price or product identifier;
• cancellation status;
• refund status;
• billing platform used.

We generally do not receive or store your complete payment card number when your payment is processed by Paddle, Apple, Google or another authorized payment provider.

3.6. Technical and Device Information

When you use the Service, we may automatically collect information such as:

• IP address;
• device type;
• operating system;
• browser type;
• device or application identifiers;
• application version;
• language settings;
• approximate region derived from IP address;
• time zone;
• crash information;
• diagnostic information;
• security logs.

3.7. Usage and Analytics Information

We may collect information about how you interact with AstroKey, such as:

• pages or screens viewed;
• buttons or features used;
• session duration;
• application opens;
• onboarding progress;
• subscription or paywall interactions;
• referral source;
• campaign attribution;
• interactions with particular Service features;
• errors and performance information.

3.8. Marketing and Attribution Information

Where permitted by law and subject to applicable consent requirements, we may process information relating to advertising and acquisition, such as:

• UTM parameters;
• advertising campaign identifiers;
• referral information;
• advertising identifiers;
• conversion events;
• campaign source;
• landing page;
• interactions with marketing campaigns.

3.9. Customer Support Information

When you contact us, we may process:

• your email address;
• account information;
• contents of your request;
• correspondence history;
• technical information necessary to investigate your request.

4. HOW WE COLLECT PERSONAL DATA

We may collect Personal Data:

4.1. Directly from You

For example when you:

• register;
• enter birth information;
• create a compatibility profile;
• subscribe;
• contact support;
• submit content;
• change account settings.

4.2. Automatically

Certain technical, device, security and usage information may be collected automatically when you use the Service.

4.3. From Service Providers

We may receive information from companies that help operate AstroKey, including payment, subscription, analytics, hosting, authentication and app distribution providers.

4.4. From Advertising and Referral Sources

Where applicable, we may receive campaign or attribution information from advertising networks or referral partners.

5. HOW AND WHY WE USE PERSONAL DATA

We may use Personal Data to:

5.1. Provide the Service

Including to:

• create and maintain your account;
• generate astrology and numerology calculations;
• create birth charts;
• provide compatibility results;
• generate personalized reports;
• provide premium functionality;
• synchronize your account across devices.

5.2. Process and Manage Subscriptions

Including to:

• determine subscription status;
• grant or remove premium access;
• synchronize entitlements;
• identify active subscriptions;
• process cancellations or refunds where applicable;
• provide subscription support.

5.3. Personalize AstroKey

We may use information you provide to tailor reports, calculations, content and functionality to you.

5.4. Operate, Maintain and Improve the Service

Including:

• analytics;
• debugging;
• crash investigation;
• quality assurance;
• performance optimization;
• feature development;
• testing.

5.5. Security and Fraud Prevention

We may process information to:

• authenticate users;
• protect accounts;
• investigate suspicious activity;
• prevent abuse;
• detect fraud;
• protect our infrastructure.

5.6. Communicate With You

We may send:

• account notifications;
• subscription information;
• security messages;
• transaction-related communications;
• important Service updates;
• responses to support requests.

5.7. Marketing

Where permitted by applicable law, we may send promotional communications or measure marketing campaigns.

Where consent is legally required, we will ask for consent before sending such communications or using non-essential tracking technologies.

You may unsubscribe from promotional emails at any time.

5.8. Compliance and Legal Obligations

We may process Personal Data where necessary to:

• comply with law;
• respond to lawful requests;
• protect legal rights;
• enforce agreements;
• investigate fraud or abuse;
• maintain required business records.

6. LEGAL BASES FOR PROCESSING — EU/EEA USERS

Where the GDPR applies, we process Personal Data using one or more lawful bases.

These may include:

6.1. Performance of a Contract

Processing necessary to provide the Service you request.

For example:

• creating your account;
• generating a birth chart;
• providing personalized functionality;
• managing your subscription;
• providing purchased premium functionality.

6.2. Consent

We may rely on consent for activities such as:

• certain cookies;
• certain analytics technologies;
• certain advertising technologies;
• promotional communications;
• optional processing where consent is the appropriate legal basis.

You may withdraw consent at any time.

Withdrawal does not affect processing that was lawful before withdrawal.

6.3. Legitimate Interests

Where permitted by law, we may process information where necessary for legitimate interests such as:

• preventing fraud;
• securing the Service;
• improving functionality;
• diagnosing technical problems;
• understanding general use of AstroKey;
• protecting our legal rights.

We balance these interests against your privacy rights and freedoms.

6.4. Legal Obligations

We may process data where necessary to comply with legal, accounting, regulatory or law-enforcement obligations.

The GDPR requires organizations to identify purposes, categories of information, legal bases and retention information in privacy notices.

7. ARTIFICIAL INTELLIGENCE AND AUTOMATED PROCESSING

Certain AstroKey functionality may use automated systems, algorithms or artificial intelligence technologies to create or assist in creating personalized content.

Information submitted for these features may be processed by technology providers acting on our behalf where necessary to generate the requested output.

We take reasonable steps to limit information supplied to such providers to information necessary for the requested functionality.

AstroKey does not intend to use automated processing to make decisions that produce legal effects concerning you or similarly significantly affect your legal rights.

Astrology, numerology and AI-generated interpretations are provided for informational, entertainment and self-reflection purposes.

8. PAYMENT AND SUBSCRIPTION PROVIDERS

8.1. Paddle

When you make a website purchase processed through Paddle, Paddle acts as Merchant of Record for the transaction.

Paddle may independently collect and process information necessary for:

• payment processing;
• fraud prevention;
• billing;
• taxes;
• invoices;
• subscription administration;
• refunds;
• regulatory compliance.

Paddle's processing of buyer information is also governed by Paddle's own privacy notices and terms.

AstroKey may receive transaction and subscription information from Paddle but generally does not receive full payment card details.

8.2. RevenueCat

AstroKey uses or may use RevenueCat to manage subscription information and access entitlements across supported platforms.

RevenueCat may process information such as:

• app user identifier;
• subscription status;
• transaction identifiers;
• product identifiers;
• purchase dates;
• renewal dates;
• entitlement information;
• platform information.

For end-user information processed on behalf of AstroKey, RevenueCat describes itself as a processor and its customer as the controller.

8.3. Apple

Where you purchase through Apple App Store, Apple processes payment and related transaction information according to Apple's own terms and privacy policies.

8.4. Google

Where you purchase through Google Play, Google processes payment and related transaction information according to Google's own terms and privacy policies.

9. OTHER SERVICE PROVIDERS AND RECIPIENTS

We may disclose Personal Data to service providers where reasonably necessary to operate AstroKey.

Categories of recipients may include:

9.1. Cloud and Hosting Providers

Providers of:

• servers;
• databases;
• content delivery;
• storage;
• infrastructure.

9.2. Analytics and Diagnostics Providers

Providers that help us understand use of the Service, diagnose errors and improve performance.

9.3. Artificial Intelligence and Technology Providers

Providers used to generate or assist with AstroKey functionality.

9.4. Communications Providers

Providers used for:

• email delivery;
• account notifications;
• customer support.

9.5. Security Providers

Providers used for:

• fraud prevention;
• cybersecurity;
• account protection;
• abuse prevention.

9.6. Payment and Subscription Providers

Including Paddle, RevenueCat, Apple and Google where applicable.

9.7. Professional Advisers

We may disclose information where reasonably necessary to:

• lawyers;
• accountants;
• auditors;
• insurers;
• consultants.

9.8. Authorities

We may disclose information where required by applicable law, lawful court order or valid governmental request.

9.9. Business Transfers

If AstroKey or substantially all relevant business assets are involved in a merger, acquisition, financing, restructuring or sale, Personal Data may be transferred as part of that transaction, subject to applicable law.

10. COOKIES AND SIMILAR TECHNOLOGIES

Our website and applications may use:

• cookies;
• SDKs;
• pixels;
• local storage;
• device identifiers;
• similar technologies.

These technologies may be used for:

10.1. Strictly Necessary Purposes

Such as:

• authentication;
• security;
• session management;
• remembering privacy choices.

10.2. Analytics

To understand how users interact with AstroKey and improve the Service.

10.3. Advertising and Attribution

Where enabled, technologies may help us:

• understand which campaign brought a user to AstroKey;
• measure conversions;
• measure advertising effectiveness;
• prevent duplicate attribution;
• deliver or measure advertising.

Where applicable law requires consent for non-essential cookies or similar technologies, those technologies should not be activated until appropriate consent has been obtained.

EU guidance emphasizes that consent must be freely given, specific, informed and unambiguous.

You may manage available choices through our cookie or privacy settings.

11. ADVERTISING AND “SALE” OR “SHARING” OF PERSONAL INFORMATION

We do not sell Personal Data for money.

However, if AstroKey uses third-party advertising pixels, advertising SDKs or cross-site advertising technologies, disclosure of identifiers and online activity to advertising partners may be treated as a “sale”, “sharing”, or use for targeted advertising under certain U.S. state privacy laws even where no money is exchanged.

Where these laws apply, eligible users may have the right to opt out.

California, for example, provides rights to opt out of sale or sharing, including certain cross-context behavioral advertising.

Where required, AstroKey will provide applicable privacy controls, such as:

Your Privacy Choices

and will process recognized opt-out preference signals, including Global Privacy Control, where legally required.

12. INTERNATIONAL DATA TRANSFERS

ASTRO KEY LLC is established in Ukraine.

Our Service is intended for users in multiple countries, and some of our technology and service providers may operate in:

• the European Economic Area;
• the United States;
• Canada;
• Ukraine;
• other countries.

As a result, Personal Data may be processed outside your country of residence.

Where required by applicable law, we use appropriate mechanisms for international data transfers, which may include:

• adequacy decisions;
• Standard Contractual Clauses;
• contractual data protection requirements;
• other legally recognized safeguards.

13. DATA RETENTION

We retain Personal Data only for as long as reasonably necessary for the purposes described in this Policy.

Retention periods depend on factors such as:

• whether your account remains active;
• whether information is necessary to provide the Service;
• applicable contractual obligations;
• security requirements;
• fraud prevention;
• legal claims;
• tax, accounting or regulatory requirements.

Account and profile data may generally be retained while your account exists.

If you request deletion, data will be deleted or anonymized where reasonably possible, except where continued retention is necessary or permitted under applicable law.

Certain transaction, financial, security or compliance records may need to be retained for longer periods.

Data may remain temporarily in secure backups after deletion from active systems until the relevant backup retention cycle expires.

14. DATA SECURITY

We use reasonable administrative, technical and organizational safeguards designed to protect Personal Data.

These may include:

• access controls;
• authentication;
• encryption where appropriate;
• infrastructure security;
• logging and monitoring;
• restricted administrative access;
• security procedures.

However, no internet-based system can guarantee absolute security.

You are responsible for protecting your AstroKey account credentials.

15. YOUR PRIVACY RIGHTS

Privacy rights vary depending on where you live.

To exercise a privacy right, contact:

[email protected]

We may need to verify your identity before fulfilling certain requests.

16. EU/EEA PRIVACY RIGHTS

If the GDPR applies to you, you may have the right to:

16.1. Access

Request information about Personal Data we process about you.

16.2. Rectification

Request correction of inaccurate or incomplete Personal Data.

16.3. Erasure

Request deletion of Personal Data in circumstances provided by law.

16.4. Restriction

Request restriction of processing in certain circumstances.

16.5. Data Portability

Receive certain Personal Data in a structured, commonly used and machine-readable format where applicable.

16.6. Objection

Object to certain processing based on legitimate interests.

16.7. Withdraw Consent

Where processing is based on consent, withdraw that consent.

16.8. Complaint

You may lodge a complaint with the competent data protection supervisory authority.

17. UNITED STATES PRIVACY RIGHTS

Depending on your state of residence and whether the relevant law applies to AstroKey, you may have rights including:

• access;
• confirmation of processing;
• correction;
• deletion;
• data portability;
• opt-out of sale;
• opt-out of sharing;
• opt-out of targeted advertising;
• limitation of certain uses of sensitive Personal Data;
• appeal of certain privacy-request decisions;
• non-discrimination for exercising privacy rights.

For California residents, applicable rights may include rights under the CCPA/CPRA.

Requests may be submitted to:

[email protected]

Where legally required, recognized Global Privacy Control signals will be treated as opt-out requests.

18. CANADIAN PRIVACY RIGHTS

Where Canadian privacy law applies, you may have rights to:

• understand why information is collected and used;
• request access to Personal Data;
• request correction of inaccurate information;
• withdraw consent subject to legal or contractual limitations;
• challenge our privacy practices.

Canadian privacy principles emphasize accountability, meaningful consent, limiting collection and retention, safeguards, transparency and individual access.

Privacy inquiries or complaints may be directed to our Privacy Contact at:

[email protected]

19. CHILDREN

AstroKey is not intended for children under 16 years of age.

We do not knowingly collect Personal Data from children under 16 without legally valid authorization where such authorization is required.

If you believe that a child has provided Personal Data to us in violation of this Policy, contact:

[email protected]

We will take appropriate steps to investigate and delete information where required.

20. THIRD-PARTY INFORMATION

Certain AstroKey features, including compatibility functionality, may allow you to provide information relating to another person.

You are responsible for ensuring that you have a lawful basis or permission to provide another person's Personal Data where required by applicable law.

Do not provide more information about another individual than is reasonably necessary to use the requested feature.

21. DO NOT TRACK

Some browsers offer “Do Not Track” settings.

Because there is no single universally adopted technical standard governing all Do Not Track signals, our response may depend on applicable law and the technologies used.

Where legally required, we honor recognized privacy preference mechanisms such as Global Privacy Control.

22. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time.

When we update it, we will change the “Last Updated” date.

If changes materially affect how we process Personal Data, we may provide additional notice where appropriate or legally required.

23. CONTACT US

For privacy requests, questions or complaints, contact:

ASTRO KEY LIMITED LIABILITY COMPANY ASTRO KEY LLC

Identification code: 46242532

Registered office:

23/1 Smilianska Street, Office 7 Cherkasy, Cherkasy Region, 18002 Ukraine

Email:

[email protected]

Website:

astro-key.com