Freya

Privacy Policy

Effective date: 21 October 2026

Controller: Yegor Terokhin

Contents
  1. Who we are
  2. What stays on your device
  3. How we use information
  4. External services and sharing
  5. Processing in other countries
  6. Storage and deletion
  7. Your rights
  8. Other important points

1. Who we are

Yegor Terokhin, an individual developer based in the Czech Republic, is responsible for Freya’s data handling. Contact: iterokhin.dev@gmail.com.

We do not operate a server-side user-profile database. Profiles and reports stay on your device. If you email us, we receive that correspondence separately.

2. What stays on your device

Setup asks for a name or nickname, gender, birth date, optional birth time, and birthplace. It currently requires all fields except birth time, although daily reflections and cards do not use birth details. A selected city can include coordinates and a time zone.

If you add another person, their details and the relationship type you select are also stored on your device.

Local records also include values derived from the information you enter, saved reports, preferences, and technical information needed to operate the App and rotate its content. We do not provide an online account or our own cloud backup.

3. How we use information

The App uses the birth details you enter to select and combine pre-written Match Report sections and individual descriptions under predefined rules. Scores are fixed illustrations, not measurements. This automatic selection can amount to profiling, but we do not use it to make decisions with legal or similarly significant effects.

The current App makes no requests to AI services. Daily reflections and card browsing work locally; the question cards do not collect written answers, record conversations, or read your contacts or messages.

Where GDPR applies, we use contract necessity for requested features only where objectively necessary, legitimate interests for support and security, legal obligations where applicable, and consent when required. Sensitive information needs an additional lawful condition where applicable. This notice and accepting Terms do not replace required consent.

4. External services and sharing

External processing happens when you choose a connected activity:

Destination apps follow their own rules and can add your account identity. We may disclose information we hold to advisers or authorities when necessary and lawful.

5. Processing in other countries

Optional email, website, Apple, and sharing services may process information outside your country, including in the United States. Your local profile database is not uploaded by the report feature.

Google identifies regional providers including Google Ireland Limited and Google LLC. It describes adequacy decisions, Data Privacy Framework participation, and standard contractual clauses for applicable transfers:
https://policies.google.com/privacy
https://policies.google.com/privacy/frameworks

GitHub, Inc. and GitHub B.V. describe international processing and applicable contractual clauses and Data Privacy Framework protections:
https://docs.github.com/en/site-policy/privacy-policies/github-general-privacy-statement

Apple identifies Apple Distribution International Limited in Ireland for EEA, UK, and Swiss personal data and describes international processing and applicable contractual clauses:
https://www.apple.com/legal/privacy/en-ww/
https://www.apple.com/legal/privacy/data/en/apple-maps/

The linked notices explain provider arrangements and how to request safeguard information. You can also contact us about processing for which Freya is responsible.

6. Storage and deletion

Local data remains while the App keeps it. Editing a profile does not necessarily rewrite saved reports. Deleting the App generally removes its local container, but Apple backups and some Keychain items may persist. We cannot remotely access your local database or restore lost reports.

We do not currently apply a fixed retention period or automatic deletion schedule to support emails. Messages may remain in Gmail until manually deleted. You can request deletion; unresolved requests, legal duties, or legal claims may require keeping some information.

Deleting Freya does not remove email, provider records, backups, or copies shared with someone else.

7. Your rights

You can edit your profile in the App. Where applicable, you may request access, correction, erasure, a portable copy, or restricted processing; object to processing based on legitimate interests; and withdraw consent. These rights have legal conditions and exceptions. There is no in-app button that erases every local record, Keychain item, backup, and external copy at once.

Email iterokhin.dev@gmail.com. We may need limited information to verify your request. Under GDPR, we normally respond within one month and explain any permitted extension within that period. Withdrawal does not make earlier lawful processing unlawful.

You may complain to your local data protection authority, including the Czech Office for Personal Data Protection:
https://uoou.gov.cz/en/consultation/contact

8. Other important points

Freya is for ages 16 and over. Do not enter identifying details about a child under 16; contact us about any such data we may hold.

We do not use in-app behavioural analytics, advertising identifiers, targeted advertising, or cross-app tracking. We do not sell personal data or share it for cross-context advertising.

We use device storage, Keychain, and encrypted connections for relevant online requests, but cannot guarantee absolute security. Protect your device and avoid sending unnecessary sensitive information.

We will update this notice when practices change, state the effective date, and communicate material changes as required. An update does not itself authorise a new use requiring consent.