1. Introduction
This Privacy Policy explains how Appyon Software & Wellness, LLC ("Auraly," "we," "us," or "our") collects, uses, discloses, and protects personal information when you use the Auraly website, mobile application, and related services (collectively, the "Services"). This Policy should be read together with our Terms of Use, which is incorporated by reference.
By using the Services, you acknowledge that your personal information will be handled as described in this Policy. If you do not agree with this Policy, please do not use the Services.
2. Scope
This Policy applies to personal information we collect through the Auraly app, our website, our checkout and cancellation portal (web.auralyapp.com/managepayments), customer support channels, and any other service we operate that links to this Policy. It applies to users in all markets we serve, including the United States, United Kingdom, Australia, New Zealand, and Brazil, with jurisdiction-specific rights described in Section 9.
3. Information We Collect
3.1 Information You Provide Directly
- Account information: email address and any other information you provide when creating an account.
- Birth and profile information: birth date, birth time, birth location, gender, relationship status, and other quiz/onboarding responses used to generate personalized astrology, numerology, and related content.
- Photos: if you choose to upload a photo for AI-generated scenarios, visual content, or personalized illustrations, we collect and process that image as described in Section 4.
- Communications: messages you send us through support, feedback forms, or app reviews.
- Payment-related information: limited billing details (such as billing name, email, and country) that our payment processors share with us to complete and manage your purchase. We do not collect or store full card numbers (see Section 3.3).
3.2 Information Collected Automatically
- Device and technical information: device type, operating system, browser type, IP address, app version, and unique device identifiers.
- Usage information: features used, screens viewed, session duration, in-app interactions, crash logs, and general engagement patterns.
- Approximate location: derived from IP address or device settings, used for currency display, localization, and fraud prevention.
3.3 Information from Third Parties
- Payment processors: our payment processors (which may include Stripe and other PCI-DSS compliant providers, orchestrated in some cases through a payment orchestration layer) share transaction status, limited billing details, and payment method type with us. We do not receive or store your full card number, CVC, or bank credentials.
- App stores: if you subscribe through Apple App Store or Google Play, those platforms share limited subscription status information with us (such as active/canceled status) to keep your account in sync.
- Analytics and attribution partners: aggregated or device-level data used to understand app performance and marketing attribution, provided by industry-standard mobile measurement and product analytics providers.
4. Sensitive Information: Photos, Birth Data, and Special Categories
Some features of Auraly involve information that receives heightened protection under privacy law:
- Photos uploaded for AI-generated scenarios or illustrations may constitute biometric or facial image data in some jurisdictions. We use uploaded photos only to generate the specific entertainment content you requested (such as an AI-generated scenario or illustration) and to improve the underlying generation systems. We do not use uploaded photos for facial recognition, identity verification, or any purpose unrelated to the feature you used.
- Birth date, time, and location are used specifically to calculate astrological charts and generate personalized content. While not "sensitive" under most laws, we treat this data with care given its personal nature.
Where required by applicable law (including the LGPD and UK/EU GDPR), our processing of this information is based on your consent, which you provide when you submit it. You may withdraw this consent at any time by contacting us at contact@auralyapp.com, which may limit or disable features that depend on that data.
5. How We Use Your Information
We use the information described above to:
- generate your personalized astrology, numerology, and AI-generated content;
- create, maintain, and secure your account;
- process payments, manage your Subscription, and administer credits;
- operate the cancellation and billing management portal;
- provide customer support and respond to your requests;
- send transactional communications (purchase confirmations, renewal notices, refund confirmations);
- send marketing communications, where permitted, and in accordance with your preferences;
- detect, investigate, and prevent fraud, abuse, and security incidents;
- comply with legal obligations and enforce our Terms of Use;
- analyze usage patterns to improve the Services and train or fine-tune the underlying AI/personalization systems, generally using aggregated or de-identified data.
6. Legal Bases for Processing (EU/UK/Brazil)
Where the GDPR, UK GDPR, or LGPD applies, we rely on the following legal bases:
- Consent — for processing birth data, photos, and other information you voluntarily submit for personalized content, and for optional marketing communications.
- Contractual necessity — for processing needed to provide the Services you subscribed to, process payments, and manage your account.
- Legitimate interests — for fraud prevention, security, analytics, and service improvement, balanced against your rights and interests.
- Legal obligation — for record-keeping, tax, and compliance requirements.
7. AI Processing and Automated Content Generation
Auraly uses artificial intelligence and algorithmic systems to generate personalized content based on the information described in Section 3. This processing:
- does not produce any legal or similarly significant effect on you (it is not used for credit decisions, employment, insurance, or similar purposes);
- is used solely to generate entertainment and self-reflection content, as described in our Terms of Use;
- may involve sending your inputs (such as quiz responses, birth data, or uploaded photos) to third-party AI model providers that process this data on our behalf, under contractual confidentiality and data protection terms. These providers process your inputs solely to return a response for the requested feature and are contractually restricted from using your data to train their own general-purpose models.
9. Your Privacy Rights
Your rights depend on where you live. We honor applicable rights regardless of location where feasible.
9.1 United States (California and other states)
If you are a California resident, the CCPA/CPRA gives you the right to:
- know what personal information we collect, use, and disclose;
- delete personal information we hold about you, subject to certain exceptions;
- correct inaccurate personal information;
- opt out of the "sale" or "sharing" of personal information (including for cross-context behavioral advertising) — we do not sell personal information for money, and you may submit any opt-out requests by emailing contact@auralyapp.com;
- limit the use of sensitive personal information;
- non-discrimination for exercising your rights.
Residents of other US states with comprehensive privacy laws (including but not limited to Virginia, Colorado, Connecticut, and Utah) have similar rights to access, correct, delete, and opt out of certain processing. You can exercise these rights by contacting us at contact@auralyapp.com.
9.2 United Kingdom and European Union
If the UK GDPR or EU GDPR applies to you, you have the right to:
- access the personal data we hold about you;
- request correction of inaccurate data;
- request erasure ("right to be forgotten");
- restrict or object to certain processing;
- receive your data in a portable format;
- withdraw consent at any time, without affecting the lawfulness of prior processing;
- lodge a complaint with your local data protection authority (in the UK, the Information Commissioner's Office).
9.3 Brazil (LGPD)
If you are located in Brazil, under the Lei Geral de Proteção de Dados (Law No. 13,709/2018), you have the right to:
- confirm the existence of processing and access your data;
- correct incomplete, inaccurate, or outdated data;
- request anonymization, blocking, or deletion of unnecessary or excessive data;
- request portability of your data to another provider;
- obtain information about the entities with which we shared your data;
- revoke your consent at any time, including for specific data such as uploaded photos or birth information;
- request review of decisions made solely through automated processing that affect your interests (note: as described in Section 7, our AI-generated content does not produce legal or similarly significant effects).
9.4 Australia and New Zealand
If the Australian Privacy Act 1988 or the New Zealand Privacy Act 2020 applies to you, you have the right to request access to and correction of the personal information we hold about you, and to lodge a complaint with the Office of the Australian Information Commissioner (OAIC) or New Zealand's Office of the Privacy Commissioner, respectively.
9.5 How to Exercise Your Rights
You can exercise any of the above rights by emailing contact@auralyapp.com with your account email and a description of your request. We may need to verify your identity before completing certain requests. We will respond within the timeframe required by applicable law.
10. Children's Privacy
The Services are not directed to, and are not intended for use by, anyone under 18 years of age, consistent with the eligibility requirement in our Terms of Use. We do not knowingly collect personal information from anyone under 18. If we become aware that we have collected personal information from someone under 18, we will delete it promptly. If you believe a minor has provided us with personal information, contact us at contact@auralyapp.com.
12. SMS / Text Message Communications
When you opt in to receive text messages from Auraly, we collect your mobile phone number and your consent to receive recurring text messages (such as daily horoscopes, astrology insights, mindfulness reminders, and related updates).
How we use this information. We use your mobile number only to send the text messages you signed up for and to operate, support, and improve our messaging program.
No sharing of mobile opt-in data. No mobile information (including your phone number and your SMS consent) will be shared with third parties or affiliates for marketing or promotional purposes. Mobile opt-in data and consent will not be sold or shared with any third parties. We may share this information only with the service providers that operate our messaging platform, strictly to deliver the messages you requested, and they are required to keep it confidential.
Message frequency and rates. Message frequency varies. Message and data rates may apply.
Opting out. You can cancel at any time by replying STOP to any message. Reply HELP for help, or contact us at contact@auralyapp.com.
13. International Data Transfers
Because we operate across the United States, United Kingdom, Australia, New Zealand, and Brazil, your information may be transferred to, stored in, and processed in countries other than your own, including the United States. Where required by applicable law, we implement appropriate safeguards for such transfers (such as standard contractual clauses or equivalent mechanisms).
14. Data Retention
We retain personal information for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements. As a general guideline, account and personalization data (including birth data and uploaded photos) are deleted or anonymized within 90 days after account deletion, while financial and tax records are retained for up to 7 years as required by applicable law. When information is no longer needed, we securely delete or anonymize it.
15. Data Security
We implement reasonable technical and organizational measures designed to protect your personal information against unauthorized access, loss, misuse, or alteration, including encryption in transit and access controls on sensitive data such as birth information and uploaded photos. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
16. Third-Party Links and Services
The Services may contain links to third-party websites or services (including payment processors and app stores) that are not operated by us. This Policy does not apply to those third parties, and we encourage you to review their own privacy policies.
17. Changes to this Policy
We may update this Privacy Policy from time to time. Material changes will be communicated by email or in-app notice, consistent with the notice provisions in our Terms of Use. The "Last Updated" date at the top of this Policy reflects the most recent revision. Your continued use of the Services after changes take effect constitutes acceptance of the revised Policy.
18. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, contact us at:
Appyon Software & Wellness, LLC
EIN: 30-1496969
Email: contact@auralyapp.com