Acknowledgment of this Privacy Notice is not processing consent. It is a notice to read. This notice is not the RU public offer and does not require acceptance of the RU Offer.
Individual entrepreneur Terentyeva Olga Borisovna INN 212885598920 · OGRNIP 320861700009447 Email: [email protected] · Phone: +7 982 144-29-14 Website: https://luminaria.fit Address: 141551, Moscow Region, Solnechnogorsk Urban District, Goluboe village, 2 Parkovy Boulevard, Building 3, Russian Federation
Minimum age: 18+.
The laws of the Russian Federation, subject to mandatory consumer protections that cannot legally be excluded.
This notice applies to users whose storage jurisdiction is GLOBAL. It does not claim that GDPR or UK GDPR applies in every country.
The primary user datastore for GLOBAL users is Supabase.
External providers still receive data needed to deliver the service (section 6). This notice does not claim that all processing happens only in Supabase or only in one country.
RU user data is not looked up in the GLOBAL datastore as a fallback, and GLOBAL user data is not looked up in the RU datastore as a fallback.
In the volume needed for the service:
If the user supplies personal data concerning another person (for example a name or date of birth for compatibility), that is not that other person’s consent and is not covered by any consent the user gives for their own personal data.
The user must have a lawful basis or authority to provide those data where required by applicable law.
| Purpose | Legal basis |
|---|---|
| Providing the service, numerology calculations, dialogue, account | Performance of the GLOBAL Terms / checkout contract, where applicable |
| Payment, paid-access records, fiscal/accounting duties | Performance of the contract and/or compliance with legal obligations |
| Support | Performance of the contract |
| Marketing messages or testimonial publication | Separate optional consent, if given; not required to use the service |
This notice does not rely on a claimed “legitimate interests” basis. Withdrawal of optional consent does not affect processing that was already lawful, or that may continue on another legal basis or because of mandatory retention.
| Recipient | Role |
|---|---|
| Supabase | primary GLOBAL datastore |
| Telegram / MAX | delivering bot messages when the user uses those channels |
| OpenAI | generating dialogue replies after applicable server-side masking/redaction of some identifiers and dates |
| Robokassa | taking payment |
| Hosting and backups | availability and restore |
| Google Analytics 4 | site analytics after optional consent (target) |
Yandex Metrica / Webvisor load only after optional analytics consent.
PostPeer and Fish Audio are marketing-production tools. This notice does not state that they receive private user chats.
The current payment provider is Robokassa.
Use of the providers above may involve processing or transfer of personal data outside the user’s country of residence. OpenAI processes dialogue content needed to generate a reply. Masking/redaction, where applied, is not anonymisation and is not a promise of full de-identification.
This notice does not invent standard contractual clauses, a data-privacy framework certification, or an EU/UK representative. Those points, territorial GDPR/UK GDPR applicability, and transfer safeguards are covered by.
Data are kept while needed for the purposes in this notice and to meet legal duties, including statutory payment and accounting records. This notice does not set one universal numeric retention period.
Payment and accounting records are not promised for immediate erasure if the account is deleted.
To provide the service the user needs to supply at least a name, a date of birth, and a working channel (website and/or messenger). Without those details the service cannot be provided as described. Optional analytics, marketing, and testimonial consents are not required to register, pay, or use ordinary dialogue.
Numerology values are calculated by the product. Text interpretations are generated with automated assistance (currently OpenAI). That is informational / entertainment / self-reflection output.
This notice does not claim automated decision-making that produces legal or similarly significant effects on the user.
The user may request, within the implemented flow and applicable law:
User-facing channels that exist today: bot commands /export and /delete, and email [email protected]. There is no dedicated “withdraw consent, keep the account” control. Optional-consent withdrawal is requested at [email protected].
Export and deletion run only in the verified GLOBAL store. The opposite jurisdiction is not searched as a fallback.
Account deletion is not a refund request.
Where GDPR, UK GDPR, or an equivalent law actually applies to the user, the user may also:
Whether those regimes apply, and any transfer mechanism or representative, remain. This section does not state that GDPR applies to every GLOBAL user.
See the Cookie Policy. Analytics tools load only after optional analytics consent.
[email protected] Address: 141551, Moscow Region, Solnechnogorsk Urban District, Goluboe village, 2 Parkovy Boulevard, Building 3, Russian Federation
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