Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") is issued by Kienmaly Mobi ("we," "us," or "our"). It governs the data practices for our mobile application, Zeva: Daily Tarot Card Reading (the "App"), and all related services (the "Services").

About Zeva: Zeva is a tarot and zodiac entertainment application that allows users to draw tarot cards, read card interpretations and browse zodiac content for self-reflection. The application provides features including but not limited to Card of the Day, Yes or No Tarot, Love Tarot, Money Tarot, 3 Cards Spread, Yearly Tarot, Daily, Weekly and Monthly Horoscope, Today's Rating, Lucky Number and Lucky Color, Zodiac Origins, Multi-language Reading (including read-aloud) and Share Reading. The following Privacy Policy sets out how your data is handled in connection with this service.

This Policy is a legally binding agreement. By downloading, installing, or using our Services, you acknowledge that you have read, understood, and agree to the data practices described herein. If you do not agree with this Policy, you must not use the Services. For the purposes of applicable data protection laws, such as the EU General Data Protection Regulation (GDPR), we are the Data Controller of your Personal Data.

2. Our Privacy Commitment

Our approach to privacy is founded on the following core principles:

2.1. Transparency: We are committed to being open and clear about how we handle your data.

2.2. Purpose Limitation: We will only collect and process your data for the specified, explicit, and legitimate purposes articulated in this Policy.

2.3. Data Minimization: We adhere to the principle of collecting only the data that is strictly necessary to provide and improve our services. The App does not require you to create an account, and does not ask for your name, date of birth, location, contacts, photos, or camera access.

2.4. Security by Design: We integrate robust security measures to protect the confidentiality, integrity, and availability of your Personal Data.

2.5. Local-First Processing: Your tarot readings, selected zodiac sign, language preference, and in-app settings are processed and stored locally on your device.

3. Data We Collect and Process

3.1. Reading and Preference Data (Processed On-Device): This is the data the App uses to deliver your readings. It includes the cards you draw, the spread you choose, your selected zodiac sign, your language preference, and your notification and display settings (collectively, "Reading Data"). Reading Data is stored locally on your device and is not uploaded to our servers.

3.2. Horoscope Content Requests: To display Daily, Weekly and Monthly Horoscope content, the App sends your selected zodiac sign and the requested time period to a third-party horoscope content provider. Like any internet request, this request includes your IP address. No other Reading Data is sent with the request.

3.3. Translation and Read-Aloud: When you switch the reading language, the App may download a language model from Google ML Kit. Translation is then performed on your device. The read-aloud feature uses the text-to-speech engine installed on your device.

3.4. Shared Readings: When you choose to share a reading, the App generates an image of the result with a QR code linking to the App, directly on your device. The image is only sent to the destination you select through your device's share menu. We do not receive a copy of the shared image.

3.5. Technical & Usage Data (Collected Automatically for Service Operation and Advertising): To ensure our App functions correctly, to resolve technical issues, and to support our advertising-based model, we automatically collect certain technical data.

3.6. Device and Network Information: Your IP address, device manufacturer and model, operating system version, screen dimensions, time zone, network state (e.g., Wi-Fi), and system language.

3.7. Application and Advertising Identifiers: Your device's advertising identifier (e.g., Google Advertising ID on Android), the App's version, unique device identifiers, and install attribution data provided by the application marketplace from which you installed the App, such as the install referrer string, which we and our attribution partners use to determine which campaign led to your installation.

3.8. Usage and Interaction Data: Information about your interactions with the Services, such as app launches, features used, readings completed, time spent on screens, and clicks. This also includes information about your interaction with advertisements shown to you, including rewarded advertisements.

3.9. Crash and Diagnostic Data: If the App crashes or encounters an error, crash logs and related diagnostic information (such as stack traces and device state at the time of the crash) are collected to help us fix the issue.

3.10. Purchase Data: If you purchase a subscription, Google Play processes your payment. We and our subscription management partner receive a purchase token, product identifier, transaction date, trial status, and subscription status in order to unlock premium features. We do not receive your payment card details.

3.11. Communications Data (Voluntarily Provided): When you voluntarily contact us for customer support, send feedback, or submit a rating comment by email, we collect your email address and the content of your communications. This data is used exclusively to respond to your inquiries.

3.12. Push Notification Data: If you allow notifications, Firebase Cloud Messaging assigns your installation a registration token so that we can deliver notifications to your device, including daily reading reminders. This token is not linked to your name or email address, and you can stop its use at any time by turning off notifications for the App in your device settings.

4. Purposes and Legal Bases for Data Processing

We only process your Personal Data when we have a valid legal basis for doing so under applicable data protection laws like the GDPR.

5. Third Party Services and Partner SDKs

We integrate third-party Software Development Kits (SDKs) to provide and maintain the full functionality of our Services, including analytics, advertising, attribution and subscription management. These partners may collect data directly from your device and typically act as independent "Data Controllers." We strongly encourage you to review their privacy policies to understand their data practices. Our primary partners include:

We may add or replace advertising mediation partners over time; the current list is maintained in this Policy and updated when it changes.

6. Application Permissions and Their Purposes

Our App requests only the minimum permissions necessary to provide its features. You are in complete control of these permissions and can manage them at any time through your device's settings menu. This section explains exactly which permissions the App may request and why we need them.

7. International Data Transfers

We operate globally, and your Personal Data may be transferred to, stored in, and processed in jurisdictions outside your country of residence, where our third-party partners operate. We ensure that all such transfers comply with applicable data protection laws by using legally-recognized transfer mechanisms like Standard Contractual Clauses (SCCs) or other safeguards required by the law of your country of residence.

8. Your Privacy Rights and Choices

You have rights concerning your Personal Data, subject to limitations provided by law.

8.1. Opt-Out of Personalized Advertising: You can limit ad tracking by resetting or deleting your device's advertising identifier through your device settings (e.g., On Android: Settings > Privacy > Ads). Where our consent management platform is shown to you, you can also change your advertising consent choices from within the App. This will limit, but not eliminate, the ads you see.

8.2. Notifications: You can turn off notifications at any time in your device settings.

8.3. Formal Rights Requests: Depending on your jurisdiction, you may have the right to Access, Rectify, or Erase the Personal Data we hold about you, or to withdraw consent you have given. Because Reading Data is stored only on your device, you can delete it at any time by clearing the App's data or uninstalling the App. Erasure requests to us will primarily apply to Technical Data and Communications Data associated with you. To exercise any of your rights, please submit a formal request to the email address provided in Section 14.

9. Data Retention

9.1. Technical and Usage Data is collected and stored by our analytics and advertising partners acting on our behalf or as independent controllers. Where we control the retention period, that data is retained for up to 24 months from the date of collection, or until it is no longer necessary for the purposes described in Section 4, whichever is earlier. Retention by independent controllers is governed by their own privacy policies, linked in Section 5.

9.2. Purchase Data is retained for as long as your subscription is active and thereafter for the period required to handle billing disputes and meet accounting or tax obligations.

9.3. We retain Communications Data (the content of your support inquiries and correspondence with us) for up to 24 months following the resolution of your inquiry, to allow us to handle any follow-up questions or complaints.

9.4. Advertising identifiers are controlled directly through your device's operating system settings; we do not separately retain them beyond your active use of the Services.

9.5. Notwithstanding the periods above, we may retain data for a longer period where required to comply with a legal obligation, to resolve disputes, or to enforce our agreements, and we will securely delete or anonymize data once it is no longer needed for these purposes.

10. Jurisdiction-Specific Provisions

We apply the data protection law of the country or state in which you reside.

10.1. For Residents of the European Economic Area (EEA), UK, and Switzerland (under GDPR): You have the rights detailed in Section 8, as well as the right to data portability, the right to object to processing based on legitimate interest, and the right to lodge a complaint with a supervisory authority. The legal bases we rely on are detailed in the table in Section 4.

10.2. For Residents of California and Other U.S. States with Consumer Privacy Laws (including CCPA/CPRA): You have the right to know what personal information is collected, to delete it, to correct it, and to opt-out of the "sharing" of your personal information for cross-context behavioral advertising. Our use of third-party advertising SDKs may be considered "sharing" or "targeted advertising." You can exercise your right to opt-out at any time by contacting us at the address in Section 14. You may additionally reset or delete your device advertising identifier as described in Section 8.1. We do not "sell" your data for monetary consideration.

10.3. For Residents of India (under the Digital Personal Data Protection Act, 2023): You have the right to access information about your personal data, to request correction and erasure, to withdraw consent, to nominate another person to exercise your rights, and to have your grievances addressed. You may contact us using the details in Section 14 for any such request or grievance.

10.4. For Users in Other Jurisdictions: Depending on the data protection laws that apply to you (including, among others, the personal data protection laws of Saudi Arabia, the United Arab Emirates, Qatar, Bahrain, Brazil's LGPD, Canada's PIPEDA, South Korea's PIPA, Australia's Privacy Act, and other applicable national or regional data protection laws), you may have similar rights to access, correct, delete, restrict, or object to the processing of your Personal Data, and to lodge a complaint with your local data protection authority. To exercise any of these rights, please contact us using the details in Section 14, and we will respond in accordance with the law that applies to you.

11. Strict Compliance with COPPA & Children's Privacy

11.1. Not Directed at Children: The Zeva App and all related Services are strictly intended for a general audience and are not directed to children under the age of 13 (or 16 in certain jurisdictions such as the EEA/UK, or such other minimum age as required by the law of your country of residence).

11.2. No Collection from Minors: We rigorously comply with the Children's Online Privacy Protection Act (COPPA) and equivalent global regulations. We do not knowingly solicit, collect, or maintain personally identifiable information from anyone under the age of 13.

11.3. Enforcement and Deletion: If we become aware that a child has provided us with Personal Data, we will take steps to delete such information immediately. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us immediately.

12. Data Security

We apply technical and organisational measures appropriate to the risk, including encryption of data in transit, restricted access to systems, and periodic review of our third-party processors. No method of transmission or storage is completely secure. If a personal data breach is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority and, where required, affected users, in accordance with applicable law.

13. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will provide notice through the App or by other means to allow you to review the changes before they become effective. Your continued use of the Services after a revision becomes effective constitutes your acceptance of the updated terms.

14. Contact Information

For any questions, concerns, or requests relating to this Privacy Policy, please contact us:

• Developer: Kienmaly Mobi
• Support Email: mobi.store99@outlook.com