Privacy Policy

Effective Date: [EFFECTIVE_DATE]

Last Updated: [EFFECTIVE_DATE]

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1. Introduction & Data Controller Identity

Welcome to Astroo, an astrology-based dating platform. This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you use our mobile application and related services (collectively, the “Service”).

Astroo is operated by Oryon Tech OÜ, a private limited company registered in the Republic of Estonia under the European Union legal framework.

Data Controller:

Entity	Details
Legal Name	Oryon Tech OÜ
Jurisdiction	Republic of Estonia, European Union
Registry Code	[COMPANY_REGISTRY_CODE]
Registered Address	[REGISTERED_ADDRESS]
VAT Number	EE[COMPANY_REGISTRY_CODE]
Contact Email	legal@astroo.app

1.1 Supervisory Authority

As a company registered in Estonia, we are subject to the supervision of the Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate):

Authority	Contact Information
Name	Andmekaitse Inspektsioon
Address	Tatari 39, 10134 Tallinn, Estonia
Phone	+372 627 4135
Email	info@aki.ee
Website	https://www.aki.ee/en

1.2 Legal Framework

This Privacy Policy complies with:

• Regulation (EU) 2016/679 – General Data Protection Regulation (GDPR)
• Isikuandmete kaitse seadus (IKS) – Estonian Personal Data Protection Act
• ePrivacy Directive 2002/58/EC as implemented in Estonian law
• Estonian Electronic Communications Act (Elektroonilise side seadus)

1.3 Scope of This Policy

This Privacy Policy applies to all users of the Astroo Service, regardless of geographic location. However, users located in the European Economic Area (EEA), United Kingdom, and Switzerland have specific rights under GDPR as detailed in Section 10.

Important Notice: By creating an Astroo account, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal data as described in this Privacy Policy. Where required by law, we obtain your explicit consent for processing special categories of personal data.

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2. Data Protection Officer

We have appointed a Data Protection Officer (DPO) to oversee our data protection strategy and ensure compliance with GDPR and Estonian data protection law.

Data Protection Officer Contact Details:

Role	Contact Information
Name	[DPO_NAME]
Email	[DPO_EMAIL]
Postal Address	Data Protection Officer, Oryon Tech OÜ, [REGISTERED_ADDRESS]
Response Time	We aim to respond to all data protection inquiries within 72 hours

You may contact our DPO regarding:

• Exercising your GDPR rights (access, rectification, erasure, etc.)
• Questions about how we process your personal data
• Complaints about our data protection practices
• Requests to withdraw consent for special category data processing
• Data protection impact assessments
• Data breach notifications
• Any other privacy or data protection concerns

Your Right to Lodge a Complaint: If you are not satisfied with our response to your data protection concerns, you have the right to lodge a complaint with the Andmekaitse Inspektsioon (see Section 1.1) or with the supervisory authority in your country of residence.

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3. Categories of Personal Data Collected

We collect and process various categories of personal data to provide, maintain, and improve the Astroo Service. This section provides a comprehensive inventory of the personal data we collect.

3.1 Account Data

Data collected during registration and account maintenance:

Data Element	Description	Required/Optional	Collection Method
Full Name	Your legal first and last name	Required	User input during registration
Email Address	Primary email for account communications	Required	User input during registration
Password	Encrypted authentication credential	Required	User input (stored as salted hash)
Date of Birth	Full birth date (DD/MM/YYYY)	Required	User input during registration
Birth Time	Time of birth (HH:MM in local timezone)	Required for chart accuracy	User input during profile setup
Birth Location	City/coordinates of birth place	Required for chart accuracy	User input with geocoding assistance
Phone Number	Mobile number for account verification	Optional	User input (if SMS verification chosen)
Account Status	Active, suspended, deleted	System-generated	Automated
Account Creation Date	Timestamp of registration	System-generated	Automated
Email Verification Status	Whether email has been verified	System-generated	Automated

3.2 Profile Data

Data you provide to create your dating profile:

Data Element	Description	Required/Optional	Collection Method
Display Name	Public-facing username	Required	User input
Profile Photos	Up to 6 photos (including main profile photo)	Required (minimum 1)	User upload
Gender Identity	Your gender (man, woman, non-binary, or custom)	Required	User selection
Sexual Orientation	Who you’re interested in meeting	Required	User selection from predefined list
Relationship Preferences	Dating goals (casual, serious, friendship, etc.)	Optional	User selection
Biography	Free-text self-description (max 500 characters)	Optional	User input
Height	Your height	Optional	User input
Education Level	Highest education completed	Optional	User selection
Occupation	Current job or profession	Optional	User input
Languages Spoken	Languages you speak	Optional	User selection (multi-select)
Interests & Hobbies	Tags/categories of interests	Optional	User selection from predefined tags
Zodiac Sign Preferences	Signs you’re most interested in	Optional	User selection (multi-select)
Location	City/region for matching purposes	Required	Derived from GPS or manual input
Search Distance	Maximum distance for potential matches	Required (default: 50km)	User selection (slider)
Age Range Preference	Preferred age range for matches	Required (default: ±5 years)	User selection (slider)

3.3 Astrological Data

Data we calculate or derive from your birth information:

Data Element	Description	Source	Storage Location
Natal Chart Data	Complete birth chart with planetary positions	Calculated from birth date/time/location	Primary database (encrypted)
Sun Sign	Zodiac sun sign	Derived from birth date	Profile metadata
Moon Sign	Zodiac moon sign	Calculated from birth date/time	Profile metadata
Rising Sign (Ascendant)	Ascendant at time of birth	Calculated from birth time/location	Profile metadata
Planetary Positions	Positions of all planets at birth	Calculated using Swiss Ephemeris	Astrological database
House Positions	12 astrological houses	Calculated from birth time/location	Astrological database
Aspects	Angular relationships between planets	Calculated from natal chart	Astrological database
Compatibility Scores	Synastry scores with other users	Calculated algorithmic data	Matching database
Daily Horoscope Preferences	Which horoscopes you view	User behavior tracking	Analytics database
Astrological Element	Fire, Earth, Air, or Water	Derived from sun sign	Profile metadata
Astrological Modality	Cardinal, Fixed, or Mutable	Derived from sun sign	Profile metadata

3.4 Usage Data

Data about how you interact with the Service:

Data Element	Description	Retention Period	Purpose
Swipe History	Records of likes, dislikes, and super likes	12 months or until account deletion	Matching algorithm optimization
Match Records	Users you’ve matched with and match timestamps	Until unmatch or account deletion	Service functionality
Conversation Metadata	Message timestamps, read receipts, response rates	12 months after conversation ends	Service quality and safety
Profile Views	Profiles you’ve viewed and who viewed you	90 days	Analytics and matching improvement
App Session Data	Login times, session duration, feature usage	90 days	Performance optimization
Search History	Filters and search criteria used	30 days	Preference learning
Reported Content	Users/content you’ve reported	24 months or until resolution	Safety and moderation
Blocked Users	Users you’ve blocked	Until unblock or account deletion	Safety feature functionality
Feature Engagement	Which features you use (e.g., horoscope section)	180 days	Product development
Notification Preferences	Which notifications you enable/disable	Until account deletion	Communication preferences

3.5 Communication Data

Data generated through your use of our messaging features:

Data Element	Description	Processing Details
Message Content	Text messages sent to matches	Encrypted in transit and at rest (AES-256)
Shared Media	Photos, videos, GIFs sent in messages	Scanned for prohibited content; encrypted storage
Voice Messages	Audio recordings sent to matches	Not transcribed; encrypted storage
Message Timestamps	When messages were sent/delivered/read	Used for read receipts and conversation sorting
Message Reactions	Emoji reactions to messages	Stored as message metadata
Deleted Message Records	Metadata about deleted messages (not content)	Retained for 30 days for safety investigations
Video Call Metadata	Call duration, participants, timestamp	Call content is NOT recorded or stored
Automated Responses	Pre-written responses you use	Used to suggest conversation starters

3.6 Technical Data

Data automatically collected from your device and app usage:

Data Element	Description	Legal Basis
IP Address	Your device’s Internet Protocol address	Legitimate interest (security, fraud prevention)
Device Information	Device model, operating system, OS version	Legitimate interest (compatibility, support)
App Version	Version of Astroo app installed	Legitimate interest (bug tracking, updates)
Mobile Advertising ID	IDFA (iOS) or AAID (Android)	Consent (for personalized ads, if enabled)
Device Language	Preferred language setting	Contract performance (interface localization)
Timezone	Device timezone setting	Contract performance (timestamp accuracy)
Network Information	Connection type (WiFi, cellular), carrier	Legitimate interest (performance optimization)
App Permissions	Permissions granted (location, camera, photos)	Consent (feature-specific)
Crash Logs	Error reports and diagnostic data	Legitimate interest (app stability)
Performance Metrics	App load times, responsiveness metrics	Legitimate interest (quality assurance)
Cookie Data	Cookie identifiers and preferences	Consent (non-essential cookies)
Unique User ID	Randomly generated identifier	Contract performance (account management)

3.7 Payment and Subscription Data

Data related to premium subscriptions and in-app purchases:

Data Element	Description	Processing Details
Subscription Tier	Free, Premium, or Premium Plus	Stored in account database
Subscription Status	Active, cancelled, expired, trial	Updated in real-time via payment processor webhooks
Transaction ID	Unique identifier for each purchase	Provided by payment processor (Apple, Google, Stripe)
Purchase Date	When subscription was purchased	Stored for billing and refund purposes
Renewal Date	Next billing date for recurring subscriptions	Used for renewal notifications
Payment Method Type	Credit card, PayPal, Apple Pay, Google Pay (type only)	No actual card numbers stored
Billing Country	Country of payment method	Required for VAT/tax compliance
Refund History	Records of refunds issued	Retained for accounting purposes (7 years)
Promotional Code Usage	Which promo codes you’ve applied	Used for marketing attribution

Important: We do NOT store your full credit card numbers, CVV codes, or complete payment credentials. Payment processing is handled by PCI-DSS compliant third-party processors (Apple App Store, Google Play Store, Stripe). We only receive transaction confirmations and identifiers.

3.8 Location Data

Data about your geographic location:

Data Element	Precision Level	Collection Method	Purpose
Precise GPS Location	Exact coordinates (lat/long)	Device GPS (with permission)	Distance calculation for matching
City-Level Location	City or neighborhood	Derived from GPS or user input	Profile display (“5km away”)
Country/Region	Country and state/region	IP address or GPS	Content localization, legal compliance
Location History	Previous locations (if user travels)	GPS tracking (only when app is active)	Update match pool when traveling

Location Data Controls:

• You can disable precise location access in device settings (app will use manually entered city)
• We do NOT track your location in the background when the app is closed
• Location data is used solely for matching and is NOT shared with advertisers
• You can change your location manually if you prefer not to use GPS

3.9 Social Media Integration Data

If you choose to connect third-party accounts:

Platform	Data We May Import	Purpose	Optional/Required
Instagram	Username, public photos, follower count	Enhance profile with additional photos	Optional
Spotify	Top artists, favorite songs	Display music taste on profile	Optional
Facebook	Name, email, profile photo	Simplified account creation	Optional

Note: Connecting social media accounts is entirely optional. We only access the specific data you authorize during the connection process, and you can disconnect these integrations at any time from your account settings.

3.10 Derived and Inferred Data

Data we generate through analysis and algorithms:

Data Element	How It’s Created	Use Case
Compatibility Scores	Algorithmic calculation based on astrological synastry	Matching and recommendation
User Attractiveness Score	Based on engagement rates (likes received, match rate)	Algorithm ranking for profile visibility
Activity Level	Frequency of logins and swipes	Prioritize active users in matching
Response Rate	How often you reply to messages	Quality signal for matching
Preference Patterns	Machine learning model of your swiping behavior	Improve match recommendations
Predicted Interests	Inferred from profile data and behavior	Conversation starter suggestions
Safety Risk Score	Behavioral analysis for potential violations	Proactive moderation
Churn Risk	Likelihood of account deletion	Retention campaigns

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4. Special Category Data (GDPR Art. 9)

Under GDPR Article 9, certain categories of personal data are considered “special categories” that require heightened protection and explicit consent. Astroo processes the following special category data:

4.1 Special Categories We Process

Special Category	Examples in Astroo Context	GDPR Article 9 Classification
Sexual Orientation	Your stated romantic/sexual preferences (e.g., “interested in women”)	Art. 9(1) - Sexual orientation
Philosophical Beliefs	Your engagement with astrology as a belief system	Art. 9(1) - Philosophical beliefs
Religious Beliefs	If you share religious practices related to astrology (e.g., Vedic astrology, spiritual practices)	Art. 9(1) - Religious beliefs
Biometric Data (Indirect)	Facial characteristics visible in profile photos (used for verification, not recognition)	Art. 9(1) - Biometric data

4.2 Legal Basis for Processing Special Category Data

We process special category data under the following GDPR Article 9(2) exceptions:

Special Category	Article 9(2) Exception	Implementation
Sexual Orientation	(a) Explicit consent	Obtained during profile setup with clear, separate consent checkbox
Philosophical Beliefs	(a) Explicit consent	You explicitly choose to use an astrology-based dating service
Religious Beliefs	(a) Explicit consent	Separate opt-in if you provide religious information
Biometric Data	(a) Explicit consent	Separate consent for photo verification feature

4.3 How We Obtain Explicit Consent

When you create an Astroo account, we present a separate, clear consent mechanism for special category data:

Example Consent Text (shown during registration):

“By using Astroo, you explicitly consent to our processing of special categories of personal data, including:

✓ Your sexual orientation and romantic preferences ✓ Your engagement with astrology and related philosophical beliefs ✓ Any religious or spiritual information you choose to share ✓ Facial characteristics in your photos (for verification purposes only)

You understand that this data will be used to provide you with astrology-based matches and personalized content. You can withdraw this consent at any time by deleting your account, but this will prevent you from using the Service.”

4.4 Safeguards for Special Category Data

We implement additional technical and organizational measures to protect special category data:

Safeguard	Implementation
Encryption	All special category data encrypted at rest using AES-256
Access Controls	Restricted to authorized personnel only (need-to-know basis)
Audit Logging	All access to special category data is logged and monitored
Data Minimization	We only collect what’s necessary for matching functionality
Anonymization	Special category data is pseudonymized in analytics systems
Staff Training	All employees handling this data receive GDPR training
DPIA Compliance	Regular Data Protection Impact Assessments (see Section 12.3)

4.5 Your Right to Withdraw Consent

You have the right to withdraw your consent for processing special category data at any time. However, please note:

• Withdrawing consent for sexual orientation data will prevent us from showing you appropriate matches
• Withdrawing consent for astrological data will make the Service non-functional (as it’s core to our service)
• The most practical way to withdraw consent is to delete your account (see Section 10.3)

To withdraw consent without deleting your account (which will severely limit functionality), contact our DPO at [DPO_EMAIL].

4.6 Making Special Category Data “Manifestly Public”

Important: By creating a dating profile on Astroo, you are choosing to make certain special category data (sexual orientation, philosophical beliefs) visible to other users. This is considered “manifestly made public” by you under GDPR Article 9(2)(e). However, we still rely on your explicit consent as the primary legal basis.

You control the visibility of this data through your privacy settings:

• Sexual orientation: Can be hidden from your public profile (will still be used for matching)
• Astrological information: Core to the service, visible on profile
• Religious beliefs: Only visible if you explicitly add them to your biography

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5. Lawful Bases for Processing (GDPR Art. 6)

Under GDPR Article 6, we must have a lawful basis for processing your personal data. This section maps our processing activities to their legal justifications.

5.1 Lawful Basis Mapping Table

Processing Activity	Data Categories	Lawful Basis (Art. 6)	GDPR Article	Explanation
Account creation and authentication	Account data, email, password	Contract performance	Art. 6(1)(b)	Necessary to provide the Service you’ve requested
Profile matching and recommendations	Profile data, astrological data, preferences	Contract performance	Art. 6(1)(b)	Core service functionality
Calculating astrological compatibility	Birth date/time/location, natal chart	Contract performance	Art. 6(1)(b)	Essential for astrology-based matching
Processing sexual orientation	Sexual orientation preferences	Explicit consent (Art. 9)	Art. 6(1)(a) + Art. 9(2)(a)	Special category data requires explicit consent
Messaging between matches	Communication data, message content	Contract performance	Art. 6(1)(b)	Necessary to enable matches to communicate
Fraud prevention and security	Technical data, IP address, device info	Legitimate interest	Art. 6(1)(f)	Protecting users and preventing abuse
Customer support	Account data, usage data, support tickets	Contract performance	Art. 6(1)(b)	Responding to your support requests
Payment processing	Payment data, subscription status	Contract performance	Art. 6(1)(b)	Fulfilling your subscription purchase
App performance optimization	Technical data, crash logs	Legitimate interest	Art. 6(1)(f)	Improving app stability and user experience
Analytics and service improvement	Pseudonymized usage data	Legitimate interest	Art. 6(1)(f)	Understanding user behavior to improve the Service
Legal compliance (e.g., tax records)	Payment records, account data	Legal obligation	Art. 6(1)(c)	Estonian Accounting Act, tax law compliance
Safety and moderation	Reported content, user behavior patterns	Legitimate interest	Art. 6(1)(f)	Protecting users from harmful content and behavior
Marketing communications (newsletter)	Email address	Consent	Art. 6(1)(a)	Sending promotional emails (opt-in required)
Personalized advertising	Advertising ID, behavioral data	Consent	Art. 6(1)(a)	Showing relevant ads (opt-in required, EEA users)
Research and development	Aggregated, anonymized data	Legitimate interest	Art. 6(1)(f)	Developing new features (data cannot identify you)
Age verification	Date of birth	Legal obligation	Art. 6(1)(c)	Ensuring compliance with 18+ age requirement
Data breach investigation	All relevant data categories	Legal obligation	Art. 6(1)(c)	GDPR Art. 33-34 breach notification obligations
Exercising legal rights	Data subject request records	Legal obligation	Art. 6(1)(c)	Responding to GDPR rights requests

5.2 Legitimate Interests Assessment

Where we rely on “legitimate interests” as our lawful basis (GDPR Art. 6(1)(f)), we have conducted a balancing test to ensure our interests do not override your fundamental rights and freedoms:

Processing Activity	Our Legitimate Interest	Your Rights Considered	Balancing Outcome
Fraud prevention	Protecting users and business from fraudulent accounts, scammers, and payment fraud	Privacy, data minimization	Justified: Fraud prevention is essential for user safety and trust
Security monitoring	Detecting and preventing unauthorized access, data breaches, and cyberattacks	Privacy of technical data	Justified: Security benefits all users; minimal privacy impact
App performance analytics	Understanding crash patterns and performance issues to improve stability	Preference for non-tracking	Justified: Data is pseudonymized; clear benefit to user experience
Content moderation	Identifying and removing prohibited content, harassment, and policy violations	Freedom of expression	Justified: User safety and legal compliance outweigh privacy impact
Behavioral analytics	Understanding user preferences to improve matching algorithms	Privacy of behavioral data	Justified: Direct benefit to matching quality; data pseudonymized

Your Right to Object: You have the right to object to processing based on legitimate interests at any time (see Section 10.7). We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

5.3 Consent Management

For processing based on consent (Art. 6(1)(a)), we ensure:

• Freely given: You can refuse consent without detriment (except where necessary for service functionality)
• Specific: Consent is granular and purpose-specific (e.g., separate consent for marketing vs. personalized ads)
• Informed: We clearly explain what you’re consenting to
• Unambiguous: Consent requires affirmative action (pre-ticked boxes are NOT used)
• Withdrawable: You can withdraw consent as easily as you gave it

How to Withdraw Consent:

• Marketing emails: Click “unsubscribe” in any email or disable in app settings
• Personalized ads: Disable in Privacy Settings > Advertising Preferences
• Special category data: Contact DPO or delete account (see Section 4.5)

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6. How We Use Your Data

We use your personal data for the following purposes:

6.1 Core Service Functionality

• Account Management: Creating, maintaining, and securing your Astroo account
• Profile Creation: Enabling you to build and customize your dating profile
• Astrological Calculations: Computing your natal chart, planetary positions, and house systems using your birth data
• Matching Algorithm: Identifying compatible users based on astrological synastry, preferences, and behavioral signals
• Compatibility Scoring: Calculating and displaying compatibility percentages with potential matches
• Discovery Features: Showing your profile to other users and showing you other users’ profiles
• Messaging: Facilitating communication between matched users
• Notification Delivery: Sending push notifications about matches, messages, and app activity
• Subscription Management: Processing premium upgrades, managing subscription status, and delivering premium features

6.2 Personalization and Recommendations

• Match Recommendations: Using machine learning to suggest profiles you’re likely to be interested in
• Conversation Starters: Suggesting icebreakers based on astrological compatibility
• Daily Horoscope Customization: Providing personalized horoscope content based on your natal chart
• Feature Suggestions: Recommending app features based on your usage patterns
• Content Curation: Customizing the explore feed with relevant astrological content

6.3 Safety, Security, and Integrity

• Identity Verification: Verifying that you are a real person through photo verification (optional feature)
• Fraud Prevention: Detecting and preventing fake accounts, bots, and scammers
• Content Moderation: Reviewing reported profiles, messages, and photos for policy violations
• Safety Tools: Enabling blocking, unmatching, and reporting features
• Security Monitoring: Detecting unauthorized access attempts and protecting against cyber threats
• Age Verification: Ensuring all users meet the 18+ age requirement
• Abuse Prevention: Identifying patterns of harassment, spam, or abusive behavior

6.4 Customer Support

• Support Request Handling: Responding to your questions, complaints, and technical issues
• Account Recovery: Helping you regain access to your account if you forget your password
• Refund Processing: Handling subscription refund requests
• Bug Reporting: Investigating and resolving technical problems you report

6.5 Analytics and Improvement

• Usage Analytics: Understanding how users interact with features to identify improvements
• A/B Testing: Testing variations of features to determine what works best
• Performance Monitoring: Tracking app load times, crashes, and errors to improve stability
• User Research: Conducting surveys and studies to inform product development
• Algorithm Optimization: Improving matching and recommendation algorithms based on outcomes

6.6 Legal and Compliance

• Legal Obligation Compliance: Fulfilling our obligations under Estonian and EU law
• Tax and Accounting: Maintaining financial records as required by Estonian Accounting Act (retention: 7 years)
• Law Enforcement Cooperation: Responding to valid legal requests from authorities (see Section 7.5)
• Terms of Service Enforcement: Investigating and addressing violations of our Terms of Service
• Data Subject Rights: Processing your GDPR rights requests (access, deletion, etc.)

6.7 Marketing and Communications (With Your Consent)

• Promotional Emails: Sending newsletters about new features, success stories, and app updates (opt-in)
• Personalized Advertising: Showing relevant ads based on your interests (opt-in for EEA users)
• Re-engagement Campaigns: Encouraging inactive users to return to the app
• Referral Programs: Managing friend referral rewards and incentives
• User Surveys: Requesting feedback about your experience (you can decline)

6.8 Purposes We Do NOT Use Your Data For

To be clear, we do NOT:

• ❌ Sell your personal data to third parties
• ❌ Use your private messages for advertising targeting
• ❌ Share your precise GPS location with other users (only approximate distance)
• ❌ Share your birth time with other users (only your sun/moon/rising signs)
• ❌ Use your data for political profiling or voter targeting
• ❌ Share your data with data brokers
• ❌ Record or store video call content
• ❌ Access your device camera or microphone without permission

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7. Data Sharing & Third-Party Processors (GDPR Art. 28)

We share your personal data with third-party service providers who assist us in delivering the Astroo Service. All processors are bound by Data Processing Agreements (DPAs) compliant with GDPR Article 28.

7.1 Third-Party Processor Categories

Processor Category	Services Provided	Data Shared	Location	Safeguards
Cloud Hosting	Server infrastructure, database hosting	All data categories (encrypted at rest)	EU (primary), US (backup)	AWS GDPR-compliant services, Standard Contractual Clauses (SCCs)
Payment Processing	Subscription billing, payment processing	Payment data, email, subscription status	EU, US	PCI-DSS compliance, processor DPAs, SCCs
Customer Support	Helpdesk ticketing system	Account data, support messages, email	EU	GDPR-compliant processor, EU data residency
Email Delivery	Transactional and marketing emails	Email address, name, email content	EU, US	SOC 2 Type II certified, SCCs, unsubscribe mechanisms
SMS Delivery	Phone verification codes	Phone number, verification codes	EU	ISO 27001 certified, data deleted after 90 days
Analytics	Usage analytics, crash reporting	Pseudonymized usage data, technical data	EU, US	IP anonymization, data minimization, SCCs
Content Delivery Network (CDN)	Image and media hosting	Profile photos, shared media	Global edge locations	Encryption in transit, access controls
Push Notifications	Mobile notification delivery	Device tokens, notification content	US (Apple), US (Google)	Apple/Google privacy policies, token encryption
Moderation Services	Content moderation, safety screening	Reported content, user-generated content	EU, US	Confidentiality agreements, GDPR training, SCCs
AI/ML Providers	Compatibility algorithms, NLP for chat	Pseudonymized behavioral data, message metadata (not content)	EU, US	Data anonymization, limited data access, SCCs
Identity Verification	Photo verification, age verification	Selfie photos, government ID (if verified)	EU	Biometric data protection, encrypted transmission, GDPR Art. 9 safeguards
Astrological Calculation Engine	Ephemeris data, chart calculations	Birth date/time/location	Self-hosted (EU)	No third-party sharing; open-source Swiss Ephemeris library

7.2 Specific Third-Party Processors

We work with the following key processors (updated [EFFECTIVE_DATE]):

Provider	Service	Data Processing Agreement	Website
Amazon Web Services (AWS)	Cloud hosting (eu-central-1 region)	AWS GDPR DPA, SCCs	https://aws.amazon.com/privacy/
Stripe	Payment processing	Stripe DPA, PCI-DSS Level 1	https://stripe.com/privacy
SendGrid	Email delivery	Twilio/SendGrid DPA, SCCs	https://www.twilio.com/legal/privacy
Google Cloud Platform	Backup storage, Firebase	Google Cloud DPA, SCCs	https://cloud.google.com/privacy
Apple Inc.	Push notifications (APNs), App Store payments	Apple Developer Agreement	https://www.apple.com/legal/privacy/
Google LLC	Push notifications (FCM), Play Store payments	Google Play Developer Agreement	https://policies.google.com/privacy
Zendesk	Customer support ticketing	Zendesk DPA, EU data residency	https://www.zendesk.com/company/privacy-and-data-protection/
Sentry	Error tracking and monitoring	Sentry DPA, EU hosting option	https://sentry.io/privacy/

Note: This list is not exhaustive. We may engage additional processors to improve the Service. We will update this Privacy Policy when we add new processors that handle significant personal data.

7.3 Data Sharing with Other Users

As a dating platform, certain data is shared with other users as part of core functionality:

Data Shared	Who Can See It	Purpose
Display name, age, photos	All users in your match pool (based on preferences)	Enabling them to discover and evaluate your profile
Biography, interests, occupation	All users who view your profile	Helping users learn about you
Zodiac signs (Sun, Moon, Rising)	All users who view your profile	Core astrological information for compatibility assessment
Approximate distance	All users who view your profile (e.g., “5km away”)	Showing proximity without revealing exact location
Compatibility score	Users you match with	Explaining why you were matched
Last active status	Users who view your profile (if enabled in settings)	Showing activity level (“Active today”, “Active this week”)
Message content	Only the specific user you’re chatting with	Facilitating conversation

You Control What’s Shared:

• Hide last active status in Privacy Settings
• Choose which photos to upload
• Decide how much information to include in your biography
• Block users to prevent them from seeing your profile

7.4 Data Sharing for Legal Reasons

We may disclose your personal data to law enforcement, regulators, or other authorities when required by law or to protect rights and safety:

Scenario	Authority	Data Shared	Legal Basis
Valid legal request	Court order, subpoena, warrant	Data specified in request	Legal obligation (Art. 6(1)(c))
Child safety concerns	National Center for Missing & Exploited Children (NCMEC), Estonian police	CSAM reports, user data	Legal obligation (EU Directive 2011/93/EU)
National security	EU/Estonian intelligence agencies	Data specified in lawful request	Legal obligation (Estonian security laws)
Tax compliance	Estonian Tax and Customs Board	Payment records, VAT data	Legal obligation (Estonian tax law)
Regulatory investigations	Andmekaitse Inspektsioon, consumer protection authorities	Requested personal data	Legal obligation (GDPR Art. 31)

Transparency Commitment:

• We will notify you of legal requests unless prohibited by law or court order
• We will publish an annual Transparency Report detailing government data requests
• We will challenge overbroad or unjustified requests

7.5 Data Sharing in Corporate Transactions

If Oryon Tech OÜ is involved in a merger, acquisition, bankruptcy, or sale of assets, your personal data may be transferred to the successor entity:

• We will notify you via email and prominent app notice before your data is transferred
• The new entity will be bound by this Privacy Policy
• You will have the right to delete your account before the transfer

7.6 No Sale of Personal Data

We do not sell your personal data. We do not and will not sell, rent, or trade your personal data to third parties for monetary or other valuable consideration. This prohibition applies regardless of your location.

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8. International Data Transfers (GDPR Art. 44-49)

Astroo primarily stores and processes data within the European Union (EU). However, some third-party processors are located outside the EU/EEA, which constitutes international data transfers under GDPR Chapter V.

8.1 Transfer Mechanisms

When we transfer personal data outside the EU/EEA, we use the following safeguards:

Transfer Mechanism	Description	When Used
Adequacy Decisions (Art. 45)	European Commission has determined the country ensures adequate protection	Transfers to UK, Switzerland, and other adequate countries
Standard Contractual Clauses (SCCs)	EU-approved contract clauses requiring equivalent GDPR protection	Transfers to US and other non-adequate countries
Binding Corporate Rules (BCRs)	Internal data protection policies approved by DPAs	Used by multinational processors (e.g., Google, Apple)
Processor Certifications	Privacy Shield successor frameworks, ISO 27001, SOC 2	Supplementary safeguards alongside SCCs

8.2 Countries Where Data May Be Processed

Country/Region	Adequacy Status	Transfer Safeguard	Processors Located There
Estonia	EU Member State	No transfer (EEA processing)	Oryon Tech OÜ (primary data controller)
Germany	EU Member State	No transfer (EEA processing)	AWS eu-central-1 (Frankfurt) data center
Ireland	EU Member State	No transfer (EEA processing)	Various EU-based processors
United Kingdom	Adequate (Brexit adequacy decision)	Art. 45 adequacy decision	Potential backup processors
Switzerland	Adequate	Art. 45 adequacy decision	Potential analytics processors
United States	Not adequate	Standard Contractual Clauses (SCCs)	AWS (backup), Apple, Google, Stripe, Sentry
Canada	Not adequate	Standard Contractual Clauses (SCCs)	Potential CDN edge locations
Australia	Not adequate	Standard Contractual Clauses (SCCs)	Potential CDN edge locations

8.3 Standard Contractual Clauses (SCCs)

For transfers to the United States and other non-adequate countries, we use the European Commission’s Standard Contractual Clauses (2021 version) as adopted by Commission Implementing Decision (EU) 2021/914.

Our SCCs include:

• Module 2: Controller-to-Processor transfers (for our service providers)
• Supplementary Measures: Additional technical safeguards such as encryption, pseudonymization, and access controls to address risks from US surveillance laws (FISA 702, Executive Order 12333)
• Data Exporter/Importer Obligations: Clear responsibilities for data protection compliance
• Audit Rights: Our right to audit processor compliance with SCCs

Transfer Impact Assessment:

We have conducted a Transfer Impact Assessment (TIA) as required by the Schrems II decision (CJEU C-311/18) for all transfers to the United States. Our assessment concludes that the supplementary measures we implement (encryption, data minimization, contractual protections) ensure an essentially equivalent level of protection to GDPR.

8.4 US-Specific Transfers

For US-based processors, we implement the following safeguards:

US Processor	Safeguard	Additional Protections
Apple Inc.	SCCs, Apple Privacy Policy	End-to-end encryption for payment data; minimal personal data shared (device tokens only)
Google LLC	SCCs, Google Cloud DPA	Data residency options; encryption in transit and at rest; limited data access
Stripe	SCCs, PCI-DSS compliance	Payment data tokenization; no full card numbers stored; encryption
AWS (US regions)	SCCs, AWS GDPR DPA	Used only for disaster recovery backups; data encrypted; infrequent access

8.5 Your Rights Regarding International Transfers

You have the right to:

• Request information about which countries your data is transferred to
• Obtain a copy of the safeguards we use (e.g., a copy of our SCCs)
• Object to transfers if you believe they do not comply with GDPR (we will assess and respond)
• Lodge a complaint with the Andmekaitse Inspektsioon if you believe transfers are unlawful

To exercise these rights, contact our DPO at [DPO_EMAIL].

8.6 CDN and Edge Computing

Our Content Delivery Network (CDN) caches images and media on edge servers globally to improve load times. This may result in temporary processing of your photos in various countries. Safeguards:

• Data is encrypted in transit and at rest
• CDN provider has GDPR-compliant DPA and SCCs
• Only publicly shared photos (not private messages) are cached
• Cache retention is limited (typically 30 days)

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9. Data Retention

We retain your personal data only as long as necessary for the purposes for which it was collected, or as required by law.

9.1 Retention Periods by Data Category

Data Category	Retention Period	Legal Basis for Retention	Deletion Trigger
Account Data	Until account deletion + 30 days	Contract performance; legal claims	User-initiated account deletion + grace period
Profile Data	Until account deletion + 30 days	Contract performance	User-initiated account deletion + grace period
Astrological Data	Until account deletion	Contract performance	User-initiated account deletion
Profile Photos	Until account deletion or photo removed	Contract performance	User removes photo or deletes account
Match History	Until unmatch or account deletion	Contract performance	User unmatches or deletes account
Message Content	Until conversation deletion or account deletion	Contract performance	User deletes conversation or account
Deleted Message Metadata	30 days after deletion	Legitimate interest (safety investigations)	Automatic after 30 days
Swipe History	12 months or until account deletion	Legitimate interest (algorithm improvement)	Whichever comes first
Usage Analytics	90 days (pseudonymized)	Legitimate interest (service improvement)	Automatic rolling deletion
IP Address Logs	90 days	Legitimate interest (security, fraud prevention)	Automatic rolling deletion
Crash Logs	180 days	Legitimate interest (app stability)	Automatic rolling deletion
Customer Support Tickets	3 years after case closure	Legitimate interest (service quality, legal claims)	Automatic after retention period
Payment Transaction Records	7 years from end of financial year	Legal obligation (Estonian Accounting Act §12)	Automatic after 7 years
VAT/Tax Records	7 years	Legal obligation (Estonian tax law)	Automatic after 7 years
Reported Content (Safety)	24 months or until investigation closure	Legitimate interest (user safety, legal compliance)	Whichever is later
Banned Account Data	Indefinite (device ID, email hash)	Legitimate interest (preventing ban evasion)	Never automatically deleted (prevents re-registration)
Consent Records	3 years after consent withdrawal	Legal obligation (GDPR accountability)	Automatic after 3 years
GDPR Rights Request Records	3 years	Legal obligation (GDPR accountability)	Automatic after 3 years
Legal Hold Data	Duration of legal proceedings + 1 year	Legal obligation (civil procedure law)	After legal matter resolution + retention period

9.2 Account Deletion Process

When you delete your Astroo account:

Immediate (within 24 hours):

• Your profile becomes invisible to other users
• You can no longer log in
• Matches are notified that you’ve unmatched (they won’t see your profile)
• Your messages are deleted from the recipient’s view

Within 30 days:

• All personal data is permanently deleted from production systems
• Profile photos are removed from CDN cache
• Astrological data is deleted
• Account data is purged

Exceptions to Deletion:

The following data may be retained even after account deletion:

Data Type	Retention After Deletion	Reason
Transaction Records	7 years	Estonian Accounting Act (legal obligation)
Safety Reports You Filed	24 months	Protecting other users; active investigations
Safety Reports Against You	24 months	Ban enforcement; pattern detection
Device/Email Hash (if banned)	Indefinite	Preventing ban evasion
Aggregated/Anonymized Data	Indefinite	Cannot re-identify you; used for research
Data Under Legal Hold	Until legal matter resolves	Court order or litigation requirement

9.3 Inactive Account Policy

If you do not log in to your account for 24 consecutive months, we will:

1. Month 22-23: Send email reminders that your account will be deleted due to inactivity
2. Month 24: Automatically delete your account using the process described in Section 9.2
3. Reason: Data minimization principle (GDPR Art. 5(1)(c)) and storage limitation (Art. 5(1)(e))

Exceptions: Premium subscribers’ accounts will not be deleted due to inactivity while subscription is active.

9.4 Anonymization and Pseudonymization

After certain retention periods, we may anonymize or pseudonymize data rather than delete it:

Technique	Definition	Use Case
Anonymization	Irreversibly removing identifiers so data can never be re-associated with you	Aggregate analytics, research, algorithm training
Pseudonymization	Replacing identifiers with pseudonyms; re-identification possible with key	Usage analytics, A/B testing (key stored separately)

GDPR Treatment:

• Anonymized data is no longer “personal data” under GDPR and is not subject to data protection rules
• Pseudonymized data is still personal data but benefits from reduced risk and relaxed requirements under GDPR Art. 25(1)

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10. Your Rights Under GDPR (Art. 15-22)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have the following rights under GDPR:

10.1 Right of Access (Art. 15)

What it means: You have the right to obtain confirmation that we are processing your personal data and to receive a copy of that data.

What you’ll receive:

• A copy of all personal data we hold about you
• Information about processing purposes, categories, recipients, retention periods
• Information about your other GDPR rights
• Information about data sources (if not collected from you)
• Information about automated decision-making (see Section 11)

How to exercise:

• In-app: Settings > Privacy > Download My Data (automated self-service)
• Email: Contact [DPO_EMAIL] with subject “GDPR Access Request”

Response time: Within 1 month (may be extended by 2 months for complex requests)

Cost: Free for the first request per year; we may charge a reasonable fee for manifestly unfounded or excessive requests

Format: JSON file (machine-readable) or PDF (human-readable), delivered via secure download link

10.2 Right to Rectification (Art. 16)

What it means: You have the right to correct inaccurate personal data and complete incomplete data.

How to exercise:

• In-app: Settings > Edit Profile (for profile data)
• In-app: Settings > Account > Edit Account Information (for account data)
• Email: Contact [DPO_EMAIL] for data you cannot edit yourself

Examples:

• Correcting your name or email address
• Updating your birth time if you entered it incorrectly
• Adding missing information to your profile

Response time: Within 1 month; corrections are applied immediately for self-service edits

10.3 Right to Erasure / “Right to Be Forgotten” (Art. 17)

What it means: You have the right to request deletion of your personal data in certain circumstances.

When this right applies:

• ✓ The data is no longer necessary for the purpose it was collected
• ✓ You withdraw consent and there’s no other legal basis for processing
• ✓ You object to processing based on legitimate interests (Art. 21) and we have no overriding grounds
• ✓ The data was unlawfully processed
• ✓ Deletion is required for compliance with EU or Estonian law

When this right does NOT apply:

• ✗ We need the data to comply with a legal obligation (e.g., tax records)
• ✗ We need the data to establish, exercise, or defend legal claims
• ✗ Processing is necessary for public interest or official authority purposes

How to exercise:

• In-app: Settings > Account > Delete My Account (permanent action)
• Email: Contact [DPO_EMAIL] with subject “GDPR Erasure Request”

Response time: Within 1 month; see Section 9.2 for deletion timeline

Warning: Account deletion is permanent and irreversible. All matches, messages, and profile data will be deleted. We recommend downloading your data (Art. 15) before deletion.

10.4 Right to Restriction of Processing (Art. 18)

What it means: You have the right to request that we stop processing your data (but not delete it) in certain circumstances.

When this right applies:

• You contest the accuracy of the data (restriction until we verify accuracy)
• Processing is unlawful but you prefer restriction over deletion
• We no longer need the data but you need it for legal claims
• You’ve objected to processing (restriction while we verify our legitimate grounds)

Effect of restriction:

• We will store the data but not process it (except with your consent or for legal claims)
• Your profile will not be shown to other users
• You will not receive matches or recommendations
• We will inform you before lifting the restriction

How to exercise: Contact [DPO_EMAIL] with subject “GDPR Restriction Request”

Response time: Within 1 month

10.5 Right to Data Portability (Art. 20)

What it means: You have the right to receive your personal data in a structured, commonly used, machine-readable format and transmit it to another service.

What data is portable:

• ✓ Data you provided to us (profile information, messages you sent)
• ✓ Data processed based on consent or contract
• ✓ Data processed by automated means

What data is NOT portable:

• ✗ Data we generated (compatibility scores, inferred preferences)
• ✗ Data processed based on legitimate interests or legal obligations
• ✗ Other users’ data (e.g., messages sent to you)

Format: JSON file compatible with common dating apps (portable format)

How to exercise:

• In-app: Settings > Privacy > Download My Data > Select “Portable Format”
• Email: Contact [DPO_EMAIL] with subject “GDPR Portability Request”

Response time: Within 1 month

10.6 Right to Object (Art. 21)

What it means: You have the right to object to processing based on legitimate interests or for direct marketing.

10.6.1 Object to Direct Marketing

Absolute right: You can object to marketing at any time, and we MUST stop.

How to exercise:

• Click “Unsubscribe” in any marketing email
• In-app: Settings > Notifications > Marketing Communications > Disable
• Email: Contact [DPO_EMAIL]

Effect: Immediate cessation of marketing emails and push notifications

10.6.2 Object to Legitimate Interest Processing

Qualified right: We will stop unless we can demonstrate compelling legitimate grounds that override your interests.

Examples:

• Objecting to behavioral analytics
• Objecting to fraud detection processing (we may not be able to honor this if it compromises security)

How to exercise: Contact [DPO_EMAIL] with specific processing activity you object to

Response time: Within 1 month; we will assess and explain our decision

10.7 Rights Related to Automated Decision-Making (Art. 22)

What it means: You have the right not to be subject to decisions based solely on automated processing (including profiling) that produce legal or similarly significant effects.

Our automated decisions:

• Compatibility scoring and match recommendations (see Section 11)
• Profile visibility ranking in discovery feed
• Automated content moderation (e.g., flagging prohibited images)

Your rights:

• Right to human review of automated moderation decisions
• Right to contest compatibility scores or ranking decisions
• Right to obtain an explanation of how algorithms work (see Section 11.2)

How to exercise: Contact [DPO_EMAIL] with subject “Automated Decision Review Request”

Note: Match recommendations do not produce “legal or similarly significant effects” under GDPR, but we still provide transparency and contestability.

10.8 Right to Withdraw Consent (Art. 7(3))

What it means: Where processing is based on consent, you can withdraw that consent at any time.

How to withdraw:

Consent Type	Withdrawal Method	Effect
Marketing emails	Click “Unsubscribe” or disable in settings	No more marketing emails; transactional emails continue
Personalized ads	Settings > Privacy > Advertising > Disable	Generic ads shown instead
Special category data	Contact [DPO_EMAIL] or delete account	Service becomes non-functional (astrology data required)
Location access	Device settings > Astroo > Location > Disable	Manual location entry required
Camera/photos access	Device settings > Astroo > Photos > Disable	Cannot upload new photos

Effect: Processing stops going forward; past processing remains lawful.

10.9 Right to Lodge a Complaint

What it means: You have the right to lodge a complaint with a data protection supervisory authority if you believe we’ve violated GDPR.

Primary supervisory authority (Estonia):

• Andmekaitse Inspektsioon (see Section 1.1 for contact details)
• File a complaint: https://www.aki.ee/en/inspectorate/activities/handling-complaints

Alternative: You may also complain to the supervisory authority in:

• Your country of habitual residence
• Your place of work
• The place of the alleged infringement

Find your local DPA: https://edpb.europa.eu/about-edpb/about-edpb/members_en

We encourage you to contact us first: Before lodging a formal complaint, please contact our DPO at [DPO_EMAIL]. We are committed to resolving data protection concerns directly and promptly.

10.10 How to Exercise Your Rights

Required Information:

To verify your identity and prevent unauthorized access, we may request:

• Your registered email address
• Account username
• Answers to security questions
• Copy of government-issued ID (for erasure or access requests only, if verification fails)

Response Timeline:

• Standard response: Within 1 month of receiving your request
• Complex requests: Up to 3 months (we will notify you if extension is needed)
• Urgent requests: We prioritize safety-related requests (e.g., data breach concerns)

Free of Charge:

• First request per year: Free
• Manifestly unfounded or excessive requests: We may charge a reasonable fee or refuse

Refusal:

If we refuse your request, we will explain why and inform you of your right to complain to the Andmekaitse Inspektsioon and seek judicial remedy.

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11. Automated Decision-Making & Profiling (GDPR Art. 22)

Astroo uses automated decision-making and profiling to provide match recommendations and personalize your experience. This section explains how these systems work and your rights regarding them.

11.1 What Automated Decisions We Make

Automated System	What It Does	Impact on You	Legal Basis
Compatibility Algorithm	Calculates astrological synastry scores between you and other users	Determines which profiles are shown to you and compatibility percentage displayed	Contract performance (core service functionality)
Match Recommendations	Ranks users in your discovery feed based on compatibility, activity, and preferences	Affects which profiles appear first in your feed	Legitimate interest (service optimization)
Profile Visibility Scoring	Determines how often your profile is shown to others based on completeness, engagement, and newness	Impacts how many views and matches you receive	Legitimate interest (fair distribution of visibility)
Automated Content Moderation	Uses AI to detect prohibited content (nudity, violence, hate speech) in photos and messages	Flagged content is hidden pending human review; severe violations may result in warnings or bans	Legitimate interest (user safety, legal compliance)
Spam/Bot Detection	Identifies fake accounts and suspicious behavior patterns	Suspected fake accounts are automatically flagged for review or restricted	Legitimate interest (fraud prevention)
Conversation Starter Suggestions	Uses NLP to suggest icebreakers based on profile compatibility	Provides optional message suggestions (you decide whether to use them)	Legitimate interest (user experience enhancement)

11.2 How Our Compatibility Algorithm Works

Transparency Commitment: We believe you deserve to understand how matches are calculated.

Astrological Compatibility Calculation:

Our algorithm analyzes synastry (compatibility between two birth charts) using the following factors:

Factor	Weight	What It Measures
Sun-Moon Compatibility	25%	Emotional harmony and core personality alignment
Venus-Mars Aspects	20%	Romantic and sexual attraction chemistry
Ascendant Compatibility	15%	First impression compatibility and lifestyle alignment
Mercury Aspects	10%	Communication style and intellectual connection
Moon-Moon Aspects	10%	Emotional needs and nurturing compatibility
Composite Chart Analysis	10%	Combined chart indicating relationship potential
House Overlays	5%	Areas of life where you’ll interact most
Harmonious vs. Challenging Aspects	5%	Balance of easy flow vs. growth-inducing tension

Additional Ranking Factors (Non-Astrological):

• Mutual preferences: Whether you fall within each other’s age/distance/gender preferences (eliminates non-matches)
• Activity level: Active users are prioritized over inactive users
• Profile completeness: Complete profiles ranked higher
• Reciprocal interest signals: If you both like similar profiles, you’re more likely to match

Compatibility Score Ranges:

• 90-100%: Exceptional astrological compatibility (very rare)
• 75-89%: Strong compatibility with harmonious aspects
• 60-74%: Moderate compatibility with some challenges
• 45-59%: Mixed compatibility (some friction, some harmony)
• Below 45%: Low astrological compatibility (still shown if other factors align)

Important: Compatibility scores are guidance, not destiny. Astrology is one lens for understanding relationships—real compatibility depends on communication, values, and effort. We encourage you to connect with people beyond just their compatibility score.

11.3 Human Review and Appeal

You have the right to human review of any automated decision that significantly affects you:

Scenario	How to Request Human Review
Your profile was hidden for policy violation	Settings > Help > Appeal Content Moderation Decision
You believe your compatibility scores are inaccurate	Contact [DPO_EMAIL] with birth data verification request
You think you’re being unfairly deprioritized	Settings > Help > Visibility Concerns
Your account was suspended for suspected bot activity	Email support@astroo.app with subject “False Positive - Human Review Requested”

Human Review Process:

1. Your request is assigned to a trained human moderator (not AI)
2. Moderator reviews the automated decision and all relevant context
3. Decision is upheld, modified, or overturned
4. You receive an explanation of the decision within 72 hours

11.4 Your Control Over Algorithmic Ranking

You can influence how the algorithm treats your profile:

Increase Your Visibility:

• Complete your profile (add photos, biography, interests)
• Stay active (log in regularly, send messages to matches)
• Enable “Boost” feature (premium) to temporarily increase visibility

Opt Out of Certain Algorithmic Features:

• Disable “Smart Recommendations”: Settings > Preferences > Use Astrological Compatibility Only (disables behavioral signals)
• Disable Profile Scoring: Contact [DPO_EMAIL] to request fixed random ordering (may reduce match quality)

Note: You cannot completely opt out of the compatibility algorithm as it is core to the Service’s value proposition. If you don’t want astrological matching, Astroo may not be the right service for you.

11.5 No Consequential Automated Decisions

Clarification: While we use extensive automation, we do NOT make automated decisions that produce legal effects or similarly significantly affect you in the way GDPR Article 22 prohibits.

Why our decisions don’t qualify as “significantly affecting” under Art. 22:

• Match recommendations do not deny you access to a service, benefit, or opportunity
• You retain full control over who you interact with
• Algorithmic ranking affects visibility but does not prevent you from manually searching/browsing
• Content moderation has human review before account suspension or ban

If you disagree with this assessment, you have the right to contest it by contacting [DPO_EMAIL].

11.6 Algorithm Auditing and Fairness

We conduct regular audits of our algorithms to prevent discrimination and ensure fairness:

• Bias Testing: Quarterly analysis to ensure algorithm doesn’t discriminate based on protected characteristics (race, religion, disability)
• Fairness Metrics: Monitoring for disparate impact across demographic groups
• External Audit: Annual third-party algorithmic fairness audit (results summarized in Transparency Report)

Anti-Discrimination Commitment:

• We do NOT allow filtering by race, religion, or ethnicity
• Zodiac sign preferences are the only belief-based filter (aligned with service purpose)
• Our algorithms do not make assumptions about your characteristics based on protected traits

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12. Data Security (GDPR Art. 32)

We implement comprehensive technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, alteration, and disclosure.

12.1 Technical Security Measures

Security Measure	Implementation	Purpose
Encryption at Rest	AES-256 encryption for all databases	Protects data if storage media is compromised
Encryption in Transit	TLS 1.3 for all data transmission	Prevents interception during transmission
End-to-End Encryption (E2EE)	Optional for messages (Signal Protocol)	Even we cannot read E2EE messages
Password Hashing	bcrypt with salt (cost factor 12)	Passwords cannot be reversed even if database is breached
Database Encryption	Encrypted database volumes (AWS RDS encryption)	Protects against unauthorized access to database layer
Multi-Factor Authentication (MFA)	Available for user accounts (TOTP, SMS)	Prevents account takeover even if password is compromised
API Authentication	OAuth 2.0, JWT tokens with short expiry	Secures API access; limits damage from token theft
Rate Limiting	API request throttling, login attempt limits	Prevents brute force attacks and abuse
Web Application Firewall (WAF)	AWS WAF with OWASP ruleset	Blocks common web exploits (SQL injection, XSS)
DDoS Protection	CloudFlare and AWS Shield	Ensures service availability during attacks
Intrusion Detection	AWS GuardDuty, log monitoring	Detects and alerts on suspicious activity
Vulnerability Scanning	Automated weekly scans (OWASP ZAP, Nessus)	Identifies and patches security vulnerabilities
Secure Code Review	Static analysis (SonarQube), peer code review	Prevents security bugs from reaching production
Dependency Scanning	Automated checks for vulnerable libraries	Keeps third-party code secure and updated

12.2 Organizational Security Measures

Security Measure	Implementation	Purpose
Access Controls	Role-based access control (RBAC); principle of least privilege	Limits employee access to only necessary data
Background Checks	Pre-employment screening for all staff with data access	Ensures trustworthiness of personnel
Confidentiality Agreements	NDAs and data protection clauses in all employment contracts	Legally binds employees to protect user data
GDPR Training	Mandatory annual training for all employees	Ensures staff understand data protection obligations
Incident Response Plan	Documented breach response procedures; quarterly drills	Enables rapid, effective response to security incidents
Data Minimization	Collect only necessary data; automatic deletion policies	Reduces risk by limiting data footprint
Pseudonymization	Replace identifiers with pseudonyms in analytics systems	Reduces risk while enabling useful analysis
Audit Logging	Immutable logs of all data access and modifications	Enables forensic investigation and accountability
Secure Development Lifecycle	Security review at each development stage	Builds security into products from inception
Third-Party Audits	Annual SOC 2 Type II audit, penetration testing	Independent verification of security controls
Physical Security	Data centers with 24/7 surveillance, biometric access	Protects servers from physical intrusion

12.3 Data Protection Impact Assessments (DPIA)

Under GDPR Article 35, we conduct Data Protection Impact Assessments for high-risk processing activities:

DPIA Completed For:

• Astrological Compatibility Profiling: Assessment of automated decision-making and special category data processing
• Photo Verification Feature: Assessment of biometric data processing
• International Data Transfers: Assessment of risks from transfers to US-based processors
• AI-Based Content Moderation: Assessment of automated content scanning

DPIA Findings:

• All high-risk processing has been assessed
• Necessary safeguards have been implemented
• Residual risks are acceptable and documented
• DPIAs are reviewed annually and after significant changes

DPIA Availability:

• Summaries are available in our annual Transparency Report
• Full DPIAs can be requested from [DPO_EMAIL] (commercially sensitive details redacted)

12.4 Data Breach Notification (GDPR Art. 33-34)

In the event of a personal data breach, we will comply with GDPR breach notification requirements:

Notification to Supervisory Authority (Art. 33):

• Timeline: Within 72 hours of becoming aware of the breach
• Authority: Andmekaitse Inspektsioon (Estonian DPA)
• Content: Nature of breach, categories and approximate number of affected users, likely consequences, measures taken

Notification to Affected Users (Art. 34):

• Trigger: If breach is likely to result in high risk to your rights and freedoms
• Timeline: Without undue delay
• Method: Email to registered address, in-app notification, public notice (if email contact not feasible)
• Content: Description of breach, likely consequences, measures we’ve taken, measures you should take, DPO contact information

What We Will NOT Do:

• ✗ Hide or delay disclosure of a breach
• ✗ Minimize the severity of a breach in communications
• ✗ Blame users for the breach

Recent Breach History:

• Astroo has not experienced any reportable data breaches as of [EFFECTIVE_DATE]
• We maintain a public breach history log at https://astroo.app/transparency/breaches

12.5 Security Limitations and Your Responsibilities

While we implement strong security measures, no system is 100% secure. You also play a role in protecting your account:

Your Security Responsibilities:

• ✓ Use a strong, unique password (not reused from other services)
• ✓ Enable two-factor authentication (Settings > Security > 2FA)
• ✓ Do not share your password with anyone
• ✓ Log out on shared devices
• ✓ Keep your email account secure (password reset mechanism)
• ✓ Report suspicious activity to support@astroo.app
• ✓ Be cautious of phishing emails pretending to be from Astroo (we will never ask for your password)

Security Best Practices:

• Use a password manager to generate and store strong passwords
• Verify emails are from @astroo.app before clicking links
• Review active sessions regularly (Settings > Security > Active Sessions)
• Report users who ask for personal information outside the app

12.6 Bug Bounty Program

We welcome responsible disclosure of security vulnerabilities:

• Scope: Astroo mobile app, API, web services
• Rewards: €100-€5,000 depending on severity
• Report: security@astroo.app (PGP key available on website)
• Policy: https://astroo.app/security/bug-bounty

Please do NOT:

• Access or modify other users’ data
• Perform denial-of-service attacks
• Publicly disclose vulnerabilities before we’ve patched them (90-day responsible disclosure window)

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13. Children’s Privacy

Astroo is strictly an 18+ service. We do not knowingly collect personal data from anyone under the age of 18.

13.1 Age Verification

We implement the following age verification measures:

Measure	Implementation
Date of Birth Collection	Required during registration; account creation blocked if age < 18
Age Gate	App Store and Google Play marked as 18+ (age-restricted download)
Terms of Service	Explicit statement that users must be 18+ to use the Service
Automated Detection	Algorithms flag accounts with suspicious age patterns for review
User Reporting	Easy reporting mechanism for suspected underage users

13.2 Removal of Underage Accounts

If we become aware that a user is under 18:

1. Immediate suspension of the account
2. Human review to verify age concern
3. Permanent deletion of the account and all associated data within 24 hours (no 30-day grace period)
4. Notification to parents/guardians if contact information is available
5. Report to authorities if required by law (e.g., suspected child exploitation)

How We Become Aware:

• User reports another user as underage
• Automated detection based on profile information or behavior
• Profile photos appear to show someone under 18
• User admits to being underage

13.3 Reporting Underage Users

If you suspect another user is under 18:

• In-app: View their profile > ⋯ Menu > Report > “Underage User”
• Email: safety@astroo.app with subject “Underage User Report” (include username)

We take these reports extremely seriously:

• All underage reports are reviewed by human moderators within 4 hours
• Suspected underage accounts are immediately suspended pending review
• We err on the side of caution—if age cannot be verified, account is deleted

13.4 Child Sexual Abuse Material (CSAM) Policy

We have zero tolerance for child sexual abuse material:

Measure	Implementation
CSAM Detection	PhotoDNA and AI-based scanning of all uploaded photos
Immediate Removal	Detected CSAM is immediately blocked and deleted
Account Ban	User who uploaded CSAM is permanently banned
Law Enforcement Report	Report to National Center for Missing & Exploited Children (NCMEC) and Estonian police within 24 hours
Data Preservation	Evidence preserved for law enforcement (exempt from deletion requests)
Employee Training	All moderators trained on CSAM identification and reporting

Legal Basis:

• EU Directive 2011/93/EU (combating sexual abuse and exploitation of children)
• Estonian Penal Code §178 (child pornography prohibition)
• GDPR Art. 6(1)(c) and Art. 9(2)(f) (legal obligation and vital interests)

13.5 Parental Rights

If you are a parent or guardian and believe your child has created an Astroo account:

1. Contact us immediately: safety@astroo.app or [DPO_EMAIL]
2. Provide evidence: Your child’s name, date of birth, and any known account information
3. We will investigate and delete the account if verified
4. We may request proof of guardianship before disclosing account information to you (GDPR Art. 8)

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14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service features.

14.1 Notification of Changes

When we make changes, we will notify you through the following methods:

Type of Change	Notification Method	Advance Notice
Minor changes (clarifications, typos, formatting)	Update “Last Updated” date at top of policy; no active notification	None required
Material changes (new data uses, new processors, reduced rights)	Email notification + in-app banner	30 days before effective date
Changes requiring new consent (new special category processing)	Explicit consent request in app; service access blocked until consent given or denied	Immediate; you choose whether to continue using Service

14.2 What Constitutes a “Material Change”

We consider the following to be material changes requiring active notification:

• Expanding the categories of personal data we collect
• Using data for significantly different purposes than originally disclosed
• Sharing data with new categories of third parties
• Reducing the scope of your rights
• Increasing data retention periods
• Changing our legal basis for processing (e.g., from consent to legitimate interest)
• Transferring data to new countries without adequate protections

14.3 Version History and Archive

We maintain a public archive of all previous versions of this Privacy Policy:

• Archive URL: https://astroo.app/legal/privacy/history
• Available Versions: All versions since launch (April 2025)
• Format: Each version timestamped with effective dates and summary of changes

Current Version:

• Version: 1.0
• Effective Date: [EFFECTIVE_DATE]
• Summary: Initial Privacy Policy for Astroo launch

14.4 Your Options When Policy Changes

When we notify you of a material change, you have the following options:

1. Accept the changes by continuing to use the Service
2. Reject the changes by deleting your account (see Section 9.2)
3. Contact us with concerns at [DPO_EMAIL] to discuss the changes

Implied Consent:

• For non-material changes, your continued use of the Service after the “Last Updated” date constitutes acceptance
• For material changes, you must affirmatively accept (e.g., click “I Accept” in app)

14.5 Notification Preferences

You can control how we notify you of policy changes:

• Settings > Notifications > Legal Updates – Enable/disable email notifications (in-app banners will always appear)
• You cannot opt out of notifications for changes that require new consent

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15. Contact Information

15.1 Data Controller Contact

Oryon Tech OÜ

• Registered Address: [REGISTERED_ADDRESS]
• Registry Code: [COMPANY_REGISTRY_CODE]
• Email: legal@astroo.app
• Website: https://astroo.app

15.2 Data Protection Officer

[DPO_NAME]

• Email: [DPO_EMAIL]
• Postal Address: Data Protection Officer, Oryon Tech OÜ, [REGISTERED_ADDRESS]
• Response Time: 72 hours for initial response; 1 month for full resolution of data protection requests

When to contact the DPO:

• Exercising GDPR rights (access, deletion, rectification, etc.)
• Questions about how we process your data
• Data protection complaints
• Consent withdrawal
• Security concerns
• Anything privacy-related

15.3 Customer Support

For general (non-privacy) support inquiries:

• Email: support@astroo.app
• In-App: Settings > Help & Support > Contact Us
• Response Time: 24-48 hours

Support Hours:

• Email support: 24/7 (monitored continuously)
• In-app chat: Monday-Friday, 9:00-18:00 EET (Estonian time)

15.4 Safety and Trust Team

For urgent safety concerns (harassment, threats, CSAM):

• Email: safety@astroo.app
• Response Time: 4 hours for urgent safety reports
• Escalation: Immediate review for CSAM or threat-to-life reports

15.5 Estonian Supervisory Authority

Andmekaitse Inspektsioon (Data Protection Inspectorate)

• Address: Tatari 39, 10134 Tallinn, Estonia
• Phone: +372 627 4135
• Email: info@aki.ee
• Website: https://www.aki.ee/en
• Complaint Form: https://www.aki.ee/en/inspectorate/activities/handling-complaints

When to contact:

• You’re not satisfied with our response to your data protection concern
• You believe we’ve violated GDPR or Estonian data protection law
• You want to lodge a formal complaint

15.6 European Data Protection Board

For EU-wide data protection guidance and information:

• Website: https://edpb.europa.eu
• Find Your National DPA: https://edpb.europa.eu/about-edpb/about-edpb/members_en

15.7 EU Online Dispute Resolution Platform

For EU consumers, you can use the European Commission’s Online Dispute Resolution (ODR) platform to resolve disputes:

• ODR Platform: https://ec.europa.eu/consumers/odr
• Purpose: Resolving online purchase disputes (subscription refunds, etc.)
• Note: Privacy complaints should be directed to the Andmekaitse Inspektsioon (Section 15.5)

15.8 Postal Contact

For written correspondence:

Oryon Tech OÜ Attn: Data Protection Officer [REGISTERED_ADDRESS]

Include in your letter:

• Your full name and registered email address (for identity verification)
• Clear description of your request or concern
• Your preferred contact method for our response
• Any relevant account information (username, transaction IDs, etc.)

15.9 Response Commitments

We commit to:

• ✓ Acknowledge all GDPR requests within 72 hours
• ✓ Provide full responses within 1 month (extendable to 3 months for complex requests)
• ✓ Respond to safety concerns within 4 hours
• ✓ Provide clear, jargon-free explanations
• ✓ Offer translation services for Estonian, Russian, and English (common languages in Estonia)

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Additional Legal Information

Jurisdiction and Governing Law

This Privacy Policy is governed by the laws of the Republic of Estonia and the European Union. Any disputes arising from this Policy shall be subject to the exclusive jurisdiction of Estonian courts.

Severability

If any provision of this Privacy Policy is found to be unenforceable or invalid under applicable law, such unenforceability or invalidity shall not render this Privacy Policy unenforceable or invalid as a whole. The unenforceable or invalid provision will be replaced with a valid provision that most closely reflects the original intent.

Language

This Privacy Policy is provided in English. Translations may be available in other languages (Estonian, Russian), but in the event of any conflict, the English version shall prevail.

Effective Date

This Privacy Policy is effective as of [EFFECTIVE_DATE] and applies to all data collected from that date forward. For data collected before this date, the previous privacy policy (if any) applies until this policy’s effective date.

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Thank you for trusting Astroo with your personal data. We are committed to protecting your privacy and ensuring transparency in how we handle your information. If you have any questions or concerns, please don’t hesitate to contact us.

Last Updated: [EFFECTIVE_DATE] Version: 1.0 Document ID: ASTROO-PRIVACY-EN-V1.0

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Oryon Tech OÜ [REGISTERED_ADDRESS] Registry Code: [COMPANY_REGISTRY_CODE] Email: legal@astroo.app Website: https://astroo.app