In order to use the App, we will ask you to enter your gender, date of birth, place of birth, and time of birth. We also automatically collect from your device language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, Facebook ID, and other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the app, to serve ads.

For improving the app and serving ads, we may share this data with third parties. Such parties include Facebook, Apple, Appsflyer, Amplitude, Crashlytics, Firebase, Fabric, Sendios. As a result of sharing this data with third parties we (1) analyze different interactions (how often users make subscriptions, how many users chose Italian as language they want to learn); (2) serve ads (and show them only to a particular group of users, for example, to subscribers).

Please read our Privacy Policy below to know more about what we do with data (Section 3), what data privacy rights are available to you (Section 6) and who will be the data controller (Section 1). If any questions will remain unanswered, please contact us at [email protected].

This Privacy Policy explains what personal data is collected when you use the Nebula mobile app (the "App") and the services provided through it (together with the App, the "Service"), how such personal data will be used, shared.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (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 Service. In such case, you must (a) delete your account using the functionality found in "Settings" in the App, or contact us and request deletion of your data; (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android); and (c) delete the App from your devices.

"GDPR" means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

"EEA" includes all current member states to the European Union and the European Economic Area.

"Process", in respect of personal data, includes to collect, store, and disclose to others.

TABLE OF CONTENT

1. PERSONAL DATA CONTROLLER
2. CATEGORIES OF PERSONAL DATA WE COLLECT
3. FOR WHAT PURPOSES WE PROCESS PERSONAL DATA
4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
5. WITH WHOM WE SHARE YOUR PERSONAL DATA
6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
7. AGE LIMITATION
8. INTERNATIONAL DATA TRANSFERS
9. CHANGES TO THIS PRIVACY POLICY
10. CALIFORNIA PRIVACY RIGHTS
11. DATA RETENTION
12. HOW "DO NOT TRACK" REQUESTS ARE HANDLED
13. SECURITY
14. CONTACT US

1. PERSONAL DATA CONTROLLER

   Obrio Limited (with registered office at Florinis 7, Greg Tower, 2nd floor, 1065, Nicosia, Cyprus) will be the controller of your personal data.

2. CATEGORIES OF PERSONAL DATA WE COLLECT

   We collect data you give us voluntarily (for example, date of birth). We also collect data automatically (for example, your IP address).

   See more
   1. Data you give us

      We may ask you to provide information about yourself when you register for and/or use the Service. This information includes: gender, date of birth, place of birth, and time of birth. You can also provide us with information about your time of birth, if you want. You may also wish to give us your email to subscribe for our newsletter.

      However, sometimes you may also need to provide us with an email address and some other information in the communication to our Support Team in order to fulfill your request or support you.

   2. Data we collect automatically
      1. Data about how you found us

         We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).

      2. Device and Location data.

         We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.

      3. Usage data

         We record how you interact with our Service. For example, we log with what features, and content you interact, how often you use the App, how long you are in the App, what sections you use, and your subscription orders.

      4. Advertising IDs

         We collect your Apple Identifier for Advertising ("IDFA") or Google Advertising ID ("AAID") (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

   3. Data you send via live chats with experts

      We process communications between users and Experts, as well as between users and members of our customer support, to provide you the Service, to assess the quality of the Service we provide, to solve any issues you may face during communication with an expert, and to ensure the Service is safe and provided in compliance with laws and our rules and policies.

3. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

   We process your personal data:

   1. To provide our Service

      This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.

      See more

      To host personal data and enable our App to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon.

      We use Firebase Performance Monitoring and Firebase Crash Reporting, which are monitoring services provided by Google. To learn more, please visit Google’s Privacy policy and Privacy and Security in Firebase.

   2. To customize your experience

      We process your personal data, such as your date of birth, to adjust the content of the Service and make offers tailored to your personal preferences. As a result of such processing, we will offer content tailored to your astrological sign.

   3. To manage your account and provide you with customer support

      We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. This includes accessing your account to address technical support requests. For this purpose, we may send you, for example, notifications or emails about the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.

   4. To communicate with you regarding your use of our Service

      We communicate with you, for example, by push notifications. These may include reminders or other information about the App. As a result, you may, for example, receive a push notification every day at a particular time reminding you to check your daily horoscope. To opt out of receiving push notifications, you need to change the settings on your device.

      See more

      The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our App’s users, as well as when they interacted with it, such as by clicking on links included in the message.

      To communicate with you we also use Firebase Cloud Messaging and Firebase Notifications, which are message sending services provided by Google. Firebase Cloud Messaging allows us to send messages and notifications to users of our App across platforms such as Android and iOS. We integrate Firebase Notifications with Firebase Analytics to create analytics-based audiences and track opening and conversion events. As a result, we can, for example, send reminders only to users who used the App more frequently. Google's privacy policy.

      We use Apple Push Notification service ("APNs"), that is a notifications service provided by Apple. APNs allows us to send information to iOS devices. Apple's privacy policy.

      We also use OneSignal Push Notification service, that is a notifications service provided by OneSignal. APNs allows us to send information to iOS and Android devices. Learn more about OneSignal’s approach to data in its Privacy Policy.

      We use Sendios, which is a marketing personalization and retention platform, to deliver tailored email messages to our users.

   5. To research and analyze your use of the Service

      This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the App and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features and sections of the App our users like more, what categories of users use our App. As a consequence, we often decide how to improve the App based on the results obtained from this processing. For example, if we discover that users frequnently use "Compatibility" section, we may focus on improving and providing more information and features to this section.

      See more

      To perform research and analysis about how users interact with our App we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Privacy policy. Opt Out.

      We use Facebook Analytics, which is a service provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people launch our App, how often users make purchases, how many users were born in Berlin, and other interactions. Lean more about Facebook’s approach to data from its Privacy policy.

      To track and analyze behavior of our App’s users (in particular, how they react to changes of the App structure, text or any other component), we use Firebase Remote Config. Firebase Remote Config is an A/B testing and configuration service provided by Google, which also enables us to tailor the content that our App’s users see (for example, it allows us to show different onboarding screens to different users). Privacy Policy and Privacy and Security in Firebase.

      Amplitude is an analytics service provided by Amplitude Inc. We use this tool to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone or tablet), unique identifiers (such as IDFA). Amplitude also allows us to track various interactions that occur in our App. As a result, Amplitude helps us to decide what features/languages we should we focus on. Amplitude provides more information on how they process data in its Privacy Policy.

      We also use Firebase Analytics, which is an analytics service provided by Google. In order to understand Google's use of data, consult Google's partner policy. Firebase Privacy information. Google’s Privacy Policy.

      To perform standard product analysis, we also use Fabric Answers, which is an analytics service provided by Crashlytics, a business division of Google. Data Processing and Security Terms. Privacy information.

   6. To send you marketing communications

      We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as for example, special offers. We may show you advertisements in our App, and send you push notifications for marketing purposes and send you newsletters and marketing campaigns via email. To opt out of receiving push notifications, you need to change the settings on your device.

   7. To personalize our ads

      We and our partners, including Facebook and Google, use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have installed our App, you might see ads of our products, for example, in your Facebook’s feed.

      How to opt out or influence personalized advertising

      iOS: On your iPhone or iPad, go to "Settings," then "Privacy" and tap "Advertising" to select "Limit Ad Track". In addition, you can reset your advertising identifier (this also may help you to see less of personalized ads) in the same section.

      Android: To opt-out of ads on an Android device, simply open the Google Settings app on your mobile phone, tap "Ads" and enable "Opt out of interest-based ads". In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads).

      To learn even more about how to affect advertising choices on various devices, please look at the information available here.

      In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
      • Network Advertising Initiative – https://optout.networkadvertising.org
      • Digital Advertising Alliance – https://optout.aboutads.info
      • Digital Advertising Alliance (Canada) – https://youradchoices.ca/choices
      • Digital Advertising Alliance (EU) – https://www.youronlinechoices.com
      • DAA AppChoices page – https://www.aboutads.info/appchoices
      See more

      We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.

      We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the App (for example, installed it). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here.

      Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.

      Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear, for example, only to users that have conducted certain actions with our App (for example, show our ads to users who have purchased a subscription). Some other examples of events that may be used for tailoring ads include, in particular, installing our App, finishing a free trial. Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.

   8. To enforce our Terms and Conditions of Use and to prevent and combat fraud, violations and misbehavior

      We use personal data to enforce our agreements, policies, rules and contractual commitments, to detect, prevent, and combat fraud, violations of law and misbehavior, including those revealed or reported as a result of communication with experts via live chats. As a result of such processing, we may, for example, analyze your correspondence in live chats and carry out investigation or share your information with others, including law enforcement agencies

   9. To comply with legal obligations

      We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)

   In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 2. This section applies only to EEA-based users.

   We process your personal data under the following legal bases:

   1. your consent;

   2. to perform our contract with you;

      Under this legal basis we:
      • Provide our Service (in accordance with our Terms and Conditions of Use)
      • Customize your experience
      • Manage your account and provide you with customer support
      • Communicate with you regarding your use of our Service
   3. for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;
      
      We rely on legitimate interests:
      • to communicate with you regarding your use of our Service

        This includes, for example, sending you push notifications reminding you to check your horoscope. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often).

      • to research and analyze your use of the Service

        Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the App easier and more enjoyable, or to introduce and test new features).

      • to send you marketing communications

        The legitimate interest we rely on for this processing is our interest to promote our Service in a measured and appropriate way.

      • to personalize our ads

        The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.

      • to enforce our Terms and Conditions of Use and to prevent and combat fraud, violations and misbehavior

        Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud violations of law, misbehavior and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use and other agreements, policies, rules and contractual commitments .and to maintain the safety and integrity of the Service.

   4. to comply with legal obligations.
5. WITH WHOM WE SHARE YOUR PERSONAL DATA

   We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 2 of this Privacy Policy. The types of third parties we share information with include, in particular:

   1. Service providers
      We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
      • cloud storage providers (Amazon)
      • data analytics providers (Facebook, Appsflyer, Firebase, Crashlytics, Amplitude, Fabric)
      • marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google, Sendios)
   2. Law enforcement agencies and other public authorities
      We may use and disclose personal data to enforce our Terms and Conditions 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.
   3. 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 share such information with any affiliated entity (e.g. parent company or subsidiary) and may 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.
6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

   To be in control of your personal data, you have the following rights:

   Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided to us in the profile section of the App.

   You may also request a copy of your personal data collected during your use of the App at [email protected].

   Deleting your personal data. You can request erasure of your personal data by sending us an email at [email protected].

   When you request deletion of 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; in such event, we will fulfill your request after we have complied with our obligations.

   Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request at [email protected].

   Additional information for EEA-based users. If you are based in the EEA, you have the following rights in addition to the above:
   The right to lodge a complaint with supervisory authority.We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
   The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send respective request at [email protected].

7. AGE LIMITATION

   We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at [email protected].

8. INTERNATIONAL DATA TRANSFERS

   We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

   In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).

9. 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, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

10. CALIFORNIA PRIVACY RIGHTS

    California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute.

    To obtain this information from us, please send an email message to [email protected] which includes "Request for California Privacy Information" on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.

    Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

11. DATA RETENTION

    We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you), which includes (but is not limited to) the period during which you have an account with the App. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

12. SECURITY

    We adopt the following secure data handling procedures: TLS 1.2 encryption, testing software for vulnerabilities and security issues, credentials and access tokens used to authenticate access to services are protected, regular software and systems updates to keep malicious actors from exploiting security vulnerabilities, logging, logs are protected from deletion.

13. HOW "DO NOT TRACK" REQUESTS ARE HANDLED

    Except as otherwise stipulated in this Privacy Policy, this App does not support "Do Not Track" requests. To determine whether any of the third-party services it uses honor the "Do Not Track" requests, please read their privacy policies.

14. 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 at [email protected].

Effective as of: October 2020