Privacy policy

• Controller: Onyx Shell LLC, a limited liability company organised under the laws of the State of Florida, United States of America (the "Provider").
• Registered in: State of Florida, United States of America.
• Privacy contact: legal@soniaoracle.com.

This Policy applies to processing carried out through soniaoracle.com, app.soniaoracle.com and the electronic communications the Provider sends to Users. It does not apply to third-party services linked from the Platform, such as Stripe’s checkout page or Google sign-in, which are governed by their own policies.

The Provider processes personal data in accordance with the principles of lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; integrity and confidentiality; and accountability. Only the data essential for each feature is required, and optional data is identified as such.

The Service can be used without revealing one’s real identity: the Provider does not require or verify the User’s real name.

• Email address and password, or Google account

  Status

  Required

  Reason

  Access to the Account, recovery and security and legal notices. An address that does not reveal one’s identity may be used.

• Date of birth

  Status

  Required

  Reason

  Confirming the User is an adult, and the basis of most Readings.

• Name the User wishes to be identified by

  Status

  Required; may be a pseudonym

  Reason

  So that Sonia can address the User by name.

• Full birth name and another or current name

  Status

  Optional

  Reason

  Numerology calculations; requested when doing a numerology Reading.

• Time and place of birth

  Status

  Optional

  Reason

  Ascendant and houses of the birth chart.

• Sex or gender and pronouns

  Status

  Optional

  Reason

  Traditions that use it in their calculations, and personalised address.

• Sexual orientation and spiritual tradition

  Status

  Optional

  Reason

  Personalisation of Readings, with explicit consent.

• Current location and profile photo

  Status

  Optional

  Reason

  Time zone and appearance of the Account.

Providing less data may reduce the accuracy of some Readings; the decision always rests with the User. For payments, Stripe processes the payment method details, which the Provider does not store.

• Identification and Account

  Data

  Email address, password (stored only as a hash), name or pseudonym, date of birth, account ID, language, avatar or profile photo. When signing in with Google: the Google account ID, email address, name and photo.

  Source

  The User, or Google if the User chooses that sign-in method.

• Data for calculating Readings

  Data

  The optional data described in the previous section that the User chooses to provide.

  Source

  The User.

• Content of consultations

  Data

  Questions, conversations with Sonia, generated Readings, dream journal entries, notes, favourites and contextual memory (people, topics and events extracted from consultations to personalise the next ones).

  Source

  The User and the Service itself.

• Reference profiles

  Data

  The permitted data of the people and pets the User adds (see the section on third-party data).

  Source

  The User.

• Transactional

  Data

  Purchase history and Rune movements, Passes, gift cards, referrals and the Stripe customer ID. The Provider does not store card details.

  Source

  The User and Stripe.

• Technical and security

  Data

  IP address, browser and device, approximate location inferred from the IP, sign-in history (including failed attempts), sessions, verification codes and rate-limit counters.

  Source

  The User’s device, automatically.

• Shared Readings

  Data

  Link, access password (as a hash), expiry date, number of views and, if sent by email, the recipient’s address.

  Source

  The User.

• Communications

  Data

  Messages sent to support and suggestions submitted through the form.

  Source

  The User.

• Aggregated statistics

  Data

  Pages visited, country, device type and referring page, without cookies or persistent identifiers.

  Source

  The browser, via a cookieless measurement tool.

If the User allows their browser to share their location, the coordinates are used solely to determine the name of the place. The User may refuse and enter the place manually.

Certain data the User may provide about themselves is specially protected: sexual orientation, beliefs or spiritual tradition, and information about health, sex life or relationships included in their consultations.

• Providing it is voluntary and the Service works without it.
• It is processed solely to personalise Readings, on the basis of the User’s explicit consent, given by entering it and withdrawable at any time by deleting it from the profile or history.
• It is not used for advertising or to build profiles unrelated to Readings, and is not disclosed to third parties other than the processors needed to provide the Service.

To adapt the tone of responses, the Service automatically identifies, using keywords in the message itself, whether it expresses urgency, sadness or anxiety. This analysis is not stored as an attribute of the User.

When the User creates a reference profile, the Provider processes that person’s data solely to generate the Readings the User requests about them.

• Permitted data: birth name and, where applicable, another or current name; date, time and place of birth; sex, optionally; relationship to the User and nicknames. For pets: name, species, breed and date of birth.
• Excluded data: health, sexual orientation, beliefs, ethnic origin, photographs, identity documents and third parties’ contact details.
• Lawful basis: the consent of the adult, which the User warrants they have obtained, or the parental authority or guardianship of whoever creates a minor’s profile.
• Limited use: this data is not used to contact the person, for advertising or for any other purpose.

People included in a reference profile, whether or not they are Users of the Service, may exercise their rights of access, rectification and deletion by writing to legal@soniaoracle.com. Reference profile data is deleted together with the Account of the User who created it.

• Managing the Account, calculating and writing Readings and keeping the history.

  Legal basis

  Performance of a contract.

• Contextual memory to personalise Readings.

  Legal basis

  Performance of a contract; explicit consent for sensitive data.

• Reference profiles.

  Legal basis

  Performance of the contract with the User; consent of the third party or parental authority.

• Managing payments, crediting Runes and Passes, refunds and accounting and tax obligations.

  Legal basis

  Performance of a contract and compliance with legal obligations.

• Security of the Account and the Service: email verification, sign-in verification, sign-in alerts, abuse limits and fraud prevention.

  Legal basis

  Legitimate interest in ensuring security.

• Service communications: verification, password recovery, security alerts, receipts and material changes.

  Legal basis

  Performance of a contract.

• Aggregated usage statistics and improvement of the Service.

  Legal basis

  Legitimate interest.

• Handling enquiries and the exercise of rights.

  Legal basis

  Compliance with legal obligations and legitimate interest.

• Responding to requests from competent authorities.

  Legal basis

  Compliance with legal obligations.

The Provider does not send commercial communications without the User’s prior consent.

To write Readings and run the conversational features, the Provider discloses to third-party artificial intelligence model providers the information strictly necessary for each consultation: the question, the conversation, the data of the profiles involved, the results of the calculations and, where relevant, the User’s contextual memory.

These providers act as processors through business services. The Provider does not authorise them to use the User’s data to train their models. The providers may retain the data for a limited period for abuse prevention and legal compliance, under their contractual terms.

The Service does not take decisions based solely on automated processing that produce legal effects concerning the User or similarly significantly affect them.

The Provider does not sell personal data or share it for cross-context behavioural advertising, including within the meaning of California and other US state privacy laws. Data is disclosed only to the following categories of processors, which act on the Provider’s behalf under contract and with appropriate safeguards:

• Hosting and delivery of the Platform

  Purpose

  Running the site and the application, and cookieless aggregated statistics.

  Location

  US and global network

• Database and storage

  Purpose

  Encrypted storage of Account information and images.

  Location

  US and global network

• Artificial intelligence models

  Purpose

  Writing Readings and conversational features.

  Location

  US

• Payment processing (Stripe)

  Purpose

  Charging purchases.

  Location

  US

• Sign in with Google (Google)

  Purpose

  Access with a Google account, at the User’s choice.

  Location

  US

• Email

  Purpose

  Sending service and security emails.

  Location

  US

• Approximate geolocation

  Purpose

  Approximate location from the IP for the sign-in history.

  Location

  US

• Mapping services

  Purpose

  Searching for and naming places; the request is made from the User’s browser.

  Location

  United Kingdom and Australia

The Provider will provide an up-to-date list of its processors to anyone who makes a justified request at legal@soniaoracle.com.

Data may also be disclosed to the persons with whom the User chooses to share a Reading or whom they invite to Nexus; to authorities and courts where there is a legal obligation; to defend the rights of the Provider or third parties; and to any successor in the event of a merger, acquisition or corporate reorganisation, subject to the same safeguards.

The Provider and most of its processors are established in the United States of America, so the data of Users resident in other countries is processed there in order to provide the Service, in performance of the contract the User enters into with the Provider. Transfers are made with the appropriate contractual safeguards required by the data protection law of the User’s country, such as Brazil’s General Data Protection Law or Argentina’s Law 25,326. The User may request information about these safeguards at legal@soniaoracle.com.

• Account, reference profiles, Readings and contextual memory: while the Account remains active. The User may delete individual Readings, reference profiles or their entire history at any time.
• Account deletion: requested from Settings and carried out after a grace period of seven (7) days, during which it may be revoked. Data is then deleted from active systems; backups are overwritten in their ordinary cycles.
• Shared Readings: the link expires after twenty-four (24) hours.
• Verification codes: expire automatically, after ten (10) minutes for sign-in codes and twenty-four (24) hours for email verification codes.
• Billing data: for the period required by applicable tax and commercial law. Stripe retains payment records in accordance with its own legal obligations.
• Communications with support: for as long as needed to handle them and thereafter for the limitation periods of any resulting claims.

The Provider applies reasonable technical and organisational measures appropriate to the risk, including:

• Encryption of all communications using TLS.
• Encryption at rest of stored information using the AES-256 standard.
• Storage of passwords using salted cryptographic hash algorithms.
• Optional sign-in verification, sign-in alerts and sign-in history.
• Access control based on the principle of least privilege and a duty of confidentiality for authorised personnel.

These measures are detailed in the Security policy.

In the event of a security breach affecting personal data, the Provider will notify the affected Users and, where applicable, the competent authorities without undue delay and within the applicable legal deadlines, which under the Florida Information Protection Act is no later than thirty (30) days. The notice will include the available information and the recommended measures.

Regardless of their place of residence, the User may exercise the following rights:

• Access: to know what data is processed and obtain a copy.
• Rectification: to correct inaccurate data; most of it can be edited directly from the profile.
• Deletion: to request deletion of the data, including the entire Account.
• Portability: to receive the data in a structured, commonly used and machine-readable format.
• Objection and restriction: to object to certain processing or request its restriction.
• Withdrawal of consent, without affecting the lawfulness of prior processing.

Requests should be sent to legal@soniaoracle.com from the Account email address. The Provider will respond within thirty (30) days, or forty-five (45) days where applicable law so provides, and may request verification of the requester’s identity. Exercising these rights is free of charge, except for manifestly unfounded or excessive requests.

14.1Rights by jurisdiction

• California and other US states with privacy laws (including Colorado, Connecticut, Texas and Virginia): the right to know, delete and correct data, to limit the use of sensitive data and not to be discriminated against for exercising these rights. Requests may be made through an authorised agent. If a request is denied, the User may appeal to the Provider and, where applicable, contact their state attorney general. The Provider does not sell or share data for targeted advertising.
• Canada (PIPEDA): the right of access and correction, and the right to complain to the Office of the Privacy Commissioner of Canada.
• Brazil (LGPD): the rights under Article 18 and the right to complain to the National Data Protection Authority (ANPD).
• Mexico: the rights of access, rectification, cancellation and objection (ARCO) under the Federal Law on the Protection of Personal Data Held by Private Parties, before the competent authority.
• Argentina (Law 25,326): the Agency for Access to Public Information is the supervisory authority.
• Colombia (Law 1581 of 2012): complaints to the Superintendence of Industry and Commerce.
• Chile, Peru and other countries of the Americas: the rights granted by national law, before the corresponding supervisory authority.

The Service is restricted to persons aged eighteen (18) or over, and minors may not use it. The Provider does not knowingly collect data from minors as Users and will delete Accounts it becomes aware belong to or are used by minors.

A minor’s data may only appear in a reference profile created by their parent or legal guardian, limited to permitted data and without sensitive data. The parent or guardian may delete the profile at any time, and the person concerned may request its deletion on reaching the age of majority.

The Platform uses only technical cookies necessary for its operation (session, language and time zone) and does not use advertising or tracking cookies. Details are set out in the Cookie policy.

The Provider may update this Policy to reflect changes in the law or the Service, indicating the date of the version in force. Material changes, such as new purposes or new categories of processors, will be communicated to the User before they apply and, where necessary, consent will be requested again.

For any matter relating to the processing of their data, the User or anyone included in a reference profile may write to legal@soniaoracle.com.