Release Date:
1. Scope and Controller
1.1 This Policy. This Policy explains how josealbertobarajas@ipaxplay.com (collectively, “we”, “the Company” or “Vela”) and you (as an individual user, “you” or “the user”) collect, use, store, share and protect your personal information when you use the Vela mobile application (the “Application”).
1.2 Content Not Covered by This Policy. The Application may contain links to third-party websites or services. Third parties are entitled to process information under their own policies, and we accept no responsibility for their privacy practices. Please review their privacy policies before using any third-party service.
1.3 Relationship with the “Vela User Service Agreement”. This Policy forms part of the “Vela User Service Agreement”. In the event of any inconsistency between the two, this Policy prevails.
2. What Information We Collect and How We Collect It
We collect only the information necessary to provide the features of the Application to you. The table below sets out all types of information we collect, by category.
2.1 Information You Provide
| Information Category | Specific Details | How Obtained | Purpose of Processing | Required |
|---|---|---|---|---|
| Account and Verification | Email address | Entered by the user | Receiving login verification codes, verifying identity, and handling account and security issues | Required |
| Personal Profile | Nickname | Entered by the user; a real name is not required | Displayed on your profile page and in relationship reports | Optional |
| Personal Profile | Gender | Selected by the user; may be left blank | Used to tailor reading preferences and content presentation to users of different genders | Optional |
| Astrological Data | Date of birth | Selected by the user | Calculating the positions of celestial bodies at the time of birth and generating the natal chart | Required (when using the astrology features) |
| Astrological Data | Time of birth | Selected by the user (an exact time or “time unknown”) | Calculating timing information such as the Ascendant and house cusps | Optional (affects calculation accuracy) |
| Astrological Data | Place of birth | Selected by the user; the Application obtains the coordinates of the location you select through the operating system | Determining the coordinates of your place of birth and the time zone and longitude in effect at that time | Required (when using the astrology features) |
| Relationship Information | Relationship status and selected questions | Entered/selected by the user | Determining the focus and output structure of the relationship report | Required when using the relationship features |
| Relationship Information | Your partner's nickname and birth data | Entered/selected by you on their behalf | Calculating the composite chart data required for the relationship report | Required when using the relationship features |
| Feedback | Communications made through the feedback channels | Provided by you | Handling account issues, technical faults, complaints and suggestions | Voluntary |
| Content | The question text you enter in the relationship features | Entered by you | Matching and generating the corresponding reading content | Required when using the relationship features |
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2.2 Information Collected Automatically
| Information Category | Specific Details | How Obtained | Purpose of Processing |
|---|---|---|---|
| Device Information | Your device's time zone | Obtained through the operating system | Converting ephemeris time to your local time zone to ensure calculation accuracy |
| Internal Account Identifiers | Internal Account ID | Generated by the system when the account is created | Identifying the account and linking your data and reports to it |
| Login and Verification Records | Login times and verification records | Generated during account creation and login verification | Protecting account security and preventing fraud and abuse |
| Content Unlock Records | Records of generated reports and unlocked content | Generated when you generate a report or unlock content | Storing generated content and unlock status, and providing “Permanent Unlock” entitlements |
| Advertising Records | Records of ad impressions, clicks, video watch completion status and reward verification | Recorded by the integrated Taku SDK and by Vela itself during ad interactions | Loading and displaying ads in Vela, measuring advertising performance, verifying reward issuance, and carrying out anti-fraud checks and advertising revenue settlement |
| Technical and Error Information | Crash logs, error messages, app version and performance data | Collected automatically by us and the necessary service providers during operation | Ensuring stable operation of the service and identifying and fixing technical faults |
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2.3 Information We Do Not Collect
- We do not collect your real name, identity document number, nationality, postal address or precise geolocation (unless you provide it voluntarily in feedback).
- We do not collect your health status, medical records or medication information. We neither require nor want you to submit any health information in the Application. Please do not include health, treatment or medication information in the questions you enter or in your nickname.
- We do not collect sensitive categories of information such as race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, biometric data or genetic data.
- Gender is one of the small number of “optional” items of information we collect, and we will not use it to infer your health, treatment, beliefs or similar.
- We do not collect your contacts, photo library, microphone or call recordings.
2.4 Special Notice on Advertising Technology Identifiers
Advertising service providers may collect advertising identifiers, device information and advertising interaction data after obtaining your consent.
- On iOS, the Application does not access IDFA unless you have expressly authorised it.
- On Android, we do not read AAID unless you have expressly consented.
- We do not load any non-essential tracking technologies (including advertising SDKs and analytics SDKs) until we have obtained your valid consent. You may withdraw that consent at any time under “Settings — Privacy” in the Application.
- Watching a rewarded ad to unlock content and consenting to optional tracking are two entirely separate matters. Refusing optional tracking does not affect your use of the basic features, nor does it affect your ability to watch rewarded ads to unlock content; conversely, consenting to optional tracking is not a condition of claiming ad rewards.
3. Special Notice: Birth Data, Partner Data and Health Information
The content of this section is critical to understanding how we handle your most sensitive information, and we ask that you read it carefully.
3.1 Birth Data
Your date of birth, time of birth and place of birth, taken individually, do not constitute special category data. We process this information because it is necessary for the core function of calculating your natal chart. However, please understand that when combined with other information, this data may in certain circumstances be used to infer your identity. Accordingly, we:
- collect it only after you provide it;
- take technical measures to separate direct identifiers such as your name and email address from your birth data in storage and in transmission;
- proactively remove direct identifiers before sending data to the chart calculation provider (see Section 6).
3.2 Partner Data (Personal Information Collected Indirectly) — Please Read Carefully
When you use the relationship report feature, you need to enter your partner’s nickname and birth data. This means that we will process personal information about a third party that was not provided to us by that individual.
- Your Undertakings. You confirm and undertake that: you have obtained that third party’s knowledge of and consent to the above information, or that you have another lawful basis for processing it; that the information you enter is accurate and lawful; and that your use will not infringe any right of that third party. If you have not obtained the other person’s consent, please do not enter their information.
- Our Processing. In line with the principle of data minimisation, the partner data required for a relationship report is used solely for the composite chart calculation concerned and is stored with your account reports under your account. It is not used for advertising, profiling, or disclosure of the partner’s name or identity to third parties.
- The Other Party’s Right to Be Informed. If your partner makes a request to us at josealbertobarajas@ipaxplay.com to access, correct or delete their personal information and can reasonably demonstrate that they are the person concerned, we will handle the request in accordance with applicable law, including deleting the relevant report data where necessary. If you would like us to delete their information, please also contact us at the same email address and we will act once we have verified the request.
3.3 Health and Mental Health Information
Astrological readings do not constitute medical or mental health advice, and we will not use anything you enter for health purposes. We do not collect health data.
Please note in particular: the text you enter in your questions, and the nickname you choose, may contain health information that you have entered voluntarily. We cannot technically prevent you from entering such content, so please do not include information about illness, treatment, medication or mental health status in your questions or nickname. Once you have entered such information, we will process it for the purposes set out in item 2.1 under “Content”, and because such information constitutes special category data, we have obtained your separate explicit consent under Article 9(2)(a) of the GDPR before processing it. You may withdraw that consent at any time (see Section 12), and once withdrawn we will delete the relevant content.
4. How We Use Information
We process your personal information only for the following purposes:
- Providing the Application — completing chart calculation, generating personal readings and daily horoscopes, generating relationship reports, matching preset reading content, presenting free astrology learning content, and account creation and login verification.
- Storing your reports and unlock status — enabling you to view previously generated reports at any time and retaining “permanent unlock” entitlements for the life of your account.
- Advertising display and content unlocking — loading and displaying third-party advertisements in Vela; measuring advertising performance; verifying completion of rewarded ads and granting the corresponding unlock entitlements; and carrying out anti-fraud checks and advertising revenue settlement.
- Ensuring the security and stability of the service — maintaining the security of your account and device, identifying and fixing technical faults, and preventing fraud and abuse.
- Responding to your requests — handling account issues, technical faults, complaints, suggestions and data subject rights requests submitted through the feedback channels.
- Complying with legal obligations — cooperating with competent authorities where required by applicable law and retaining the necessary records for the periods required by law.
- To the extent of your separate consent, conducting optional tracking and personalised advertising.
- To the extent permitted by law, improving product functionality and user experience.
We do not use your personal information to make decisions based on automated processing that produce legal or similarly significant effects (see Section 13).
5. Legal Bases for Processing Personal Information
Under the law, we process your personal information on the following legal bases:
| Processing Activity | Applicable Legal Basis |
|---|---|
| Account creation, login and verification; saving reports and unlock status; providing chart calculation, readings and relationship reports | Performance of a contract necessary for the provision of the Service — that is, the contract for the Service that you enter into by downloading and using the Application |
| Responding to your enquiries, complaints and data subject rights requests | Performance of a contract necessary for the provision of the Service; and our legitimate interests, namely handling your affairs properly |
| Safeguarding service security and stability, preventing fraud and abuse, and maintaining technical records | Our legitimate interests, namely maintaining the security and proper operation of the Application and its users |
| Advertising display and measurement, rewarded ad reward verification, settlement and anti-fraud checks | Performance of a contract necessary for the provision of the Service (in providing the unlock features you have chosen); and our legitimate interests (advertising operations and anti-fraud measures) |
| Storing collaboration and content unlock records | Performance of a contract necessary for the provision of the Service |
| Optional tracking and personalised advertising | Your consent, which you may withdraw at any time |
| Special category data that may be contained in content you enter (such as health information) | Your separate explicit consent, which you may withdraw at any time |
| Compliance with legal obligations and retention of statutory records | Legal obligation |
| Protecting our legitimate interests and those of third parties, and responding to legal proceedings | Our legitimate interests, where necessary and to the extent necessary |
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Regarding “Required” and “Optional”: the information marked as “Optional” in the table above (nickname, gender, time of birth) does not affect your use of the core features. If you do not provide it, the corresponding content will be less personalised, but you will not be prevented from using the Application.
7. Third-Party Services
7.1 Chart Calculation Provider. See Section 6.4.
7.2 Advertising Services. Vela displays third-party advertisements through Taku and the advertising partners actually integrated. You may choose to watch a rewarded ad to unlock the corresponding daily horoscope or relationship report.
7.3 Watching a rewarded ad and consenting to optional tracking are separate choices. Where tracking permission is required, Vela will request it separately and does not make consent to optional tracking a condition of claiming ad rewards.
7.4 AI-Assisted Tools. Vela V1.0 does not connect any large language model to process user information or to generate readings in real time. Certain materials and preset copy were produced with the assistance of AI-Assisted Tools, but no real user information or other real Personal Information was provided to those tools. If a future version introduces AI generation capabilities, we will update this Policy before enabling them and will separately obtain your consent for the corresponding data processing.
9. Information Retention Periods
We retain your personal information only for as long as necessary to achieve the purposes of collection, or for the period required by law.
| Information Type | Retention Period |
|---|---|
| Account data (email address, nickname, gender, birth data and relationship information) | For the duration of the account. Within 30 days of receiving a deletion request it is deleted or irreversibly anonymised |
| Generated reports and readings, permanent unlock records | For the duration of the account; deleted together with the account when it is deleted (except where retention is required by law) |
| Login and verification records, device time zone | For the duration of the account and for up to 12 months after the account is terminated |
| Ad impression, click and reward verification records | From the date of recording, for a maximum of 13 months |
| Technical and error information (crash logs) | From the date of recording, for a maximum of 24 months |
| Feedback and ticketing communications | For up to 24 months after the matter has been resolved |
| Statutory records (where applicable) | For the period prescribed by applicable law (typically 5 to 10 years after the transaction) |
| Records of withdrawn consent | For up to 3 years after withdrawal, to evidence the time of withdrawal and the compliance of the processing |
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Account deletion. After you delete your account in the Application, we immediately cease the ordinary use of your account and delete or irreversibly anonymise your account data within 30 days. The “Permanent Unlock” entitlements end on deletion of the account (see the “Vela User Service Agreement”). Processing records generated by the exercise of your data subject rights will be deleted or anonymised within a reasonable period.
10. Information Security
10.1 Security Measures. We apply technical and organisational measures consistent with industry standards to protect your personal information, including but not limited to: transport layer encryption (HTTPS/TLS), encryption at rest, access control and least privilege, internal data classification, vendor security management, regular security assessments and vulnerability remediation, log auditing and anti-fraud mechanisms.
10.2 Your Cooperation. Please keep your account credentials safe, do not share your verification codes with anyone else, and take responsibility for activity under your account.
10.3 No Absolute Security. Given the limitations of technology and the various attack vectors that may exist, we cannot guarantee absolute security. If a personal data breach occurs that may affect your personal information, we will notify you and the relevant supervisory authority in accordance with applicable law.
11. Your Rights
Under applicable law, you have the following rights.
11.1 List of Rights
| Right | Description |
|---|---|
| Access | Obtain a copy of the personal information we hold about you, together with information on the purposes of processing, categories, processors and retention periods. |
| Rectification | Request the correction of inaccurate or incomplete personal information. |
| Erasure | Request the deletion of your personal information (except where retention is required by law). You may also delete your account directly in the Application. |
| Restriction of Processing | Request that processing be restricted in certain circumstances. |
| Portability | Obtain your data in a structured, commonly used and machine-readable format and transmit it to a provider you specify. |
| Objection | Where processing is based on legitimate interests, you have the right to object at any time; where it is based on direct marketing, you have the right to object at any time. |
| Withdrawal of Consent | Withdraw any consent-based processing, without affecting the lawfulness of processing carried out before the withdrawal. |
| No Subject to Solely Automated Decision-Making | Not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects. See Section 13. |
| Complaint | Lodge a complaint with a data protection supervisory authority. See Section 16. |
| Right to Be Informed | If your information was collected indirectly because another person (such as a partner) provided it to us, you have the right to be informed of how we process your information and its source. This applies principally to the partner data scenario; see Section 3. |
| No Sale / No Sharing of Personal Information | The right to require us not to sell or share your personal information. |
| Restriction of the Use of Sensitive Personal Information | The right to limit our use of sensitive personal information. |
| Correction | The right to require the correction of inaccurate information. |
| Information and Erasure | The right to be informed of what information we collect and its source and purpose, and the right to require its deletion. |
| Non-Discrimination | We will not discriminate against you for exercising your rights. |
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11.2 How to Exercise Your Rights
Please submit requests by the following means:
- In the Application: “Settings — Privacy” (if this option is not yet available, you may contact us by email);
- By email: josealbertobarajas@ipaxplay.com
Please state in your request the right you wish to exercise, the email address you registered with, and information sufficient to identify you. We may need to verify your identity in order to safeguard account security.
11.3 Response Times
- We will respond within a maximum of one month of receiving your request; where the matter is complex, this may be extended by two months, and we will explain the reason for the extension within the first month.
11.4 No Charge
Except that we may charge a reasonable administrative fee for repeated, excessive or unfounded requests to the extent permitted by law, we do not charge a fee.
12. Privacy of Minors
12.1 Scope. The Application is provided only to users aged 18 or over, and we do not provide the service to minors, nor do we knowingly collect personal information from minors.
12.2 Discovery of Data Concerning Minors. If we discover that we have collected personal information from a user under the age of 18, we will delete such information as soon as possible. If you believe that we have wrongly collected information about a minor, please contact us at josealbertobarajas@ipaxplay.com.
12.3 Age Verification. We may determine your age by requiring confirmation of your age, checking proof of identity, or relying on age rating information provided by the operating system and app store. If we cannot be satisfied that you are aged 18 or over, we may refuse to open an account for you or suspend the service.
13. Changes to This Policy
13.1 Right to Amend. We may amend this Policy in response to changes in laws and regulations, regulatory requirements or operational needs.
13.2 Notification. The amended Policy will be published in the Application. Where a material change is involved, we may give you reasonable notice before it takes effect by means of a prominent notice in the Application, a notification sent to your registered email address or other reasonable means.
13.3 Re-requesting Consent. Where a change involves a new processing purpose, a new processor, a new cross-border transfer, or requires new consent, we will request your consent again before the change takes effect.
13.4 Continued Use. If you continue to use the Application after a change takes effect, you are deemed to have accepted the amended Policy (except in respect of matters requiring separate consent).
15. Contact Details
15.1 Email: josealbertobarajas@ipaxplay.com