Ovinchi Privacy Policy

This summary allows for layered reading. The following sections contain the complete information and prevail in case of doubt.

The data controller is Fernando Granado Castillo, Tax ID (NIF) 02668882P, domiciled at Calle Francisco Rivera, 28200 San Lorenzo del Escorial, Madrid, Spain. Privacy and contact email: ovinchi@ovinchi.com.

This document applies to the Ovinchi mobile app, the ovinchi.com website, linked forms and associated digital services. Ovinchi has not appointed a Data Protection Officer. Queries are handled through the email above.

Ovinchi processes data in accordance with the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality.

• •Only data appropriate for each feature will be requested.
• •Optional data will not prevent account creation or access to features that do not need it.
• •Personal content will not be used for personalized advertising nor sold to third parties.
• •Consent-based features can be declined or disabled without affecting the rest of the service, unless the processing is essential to run that feature.

Most data comes directly from the user. Some identifiers and technical data are generated when using the app, logging in, receiving notifications or making a purchase.

The date, time and place of birth may be needed to run a BaZi, Human Design or astrology chart. They do not need to be requested before the user chooses a feature that needs them. Sex and marital status are optional and, when provided, are used to adapt certain interpretations. They will not prevent registration or the use of other features.

The user must ensure that data is correct and keep it up to date. When the exact birth time is unknown, Ovinchi may allow an estimate, explaining that the result may be less accurate.

If Ovinchi detects an account belonging to a user under 14, it may suspend it and request the intervention of their legal representative, who may request access or deletion by writing to ovinchi@ovinchi.com. Ovinchi does not deliberately request information from minors that is not necessary for the service.

Journals, dreams, queries, goals or emotional states may incidentally reveal information about health, beliefs, sexuality, origin or other specially protected categories. Ovinchi does not require entering that information. When it is necessary for a chosen feature, explicit consent will be requested and the consequences of not granting it will be explained.

• •Do not include sensitive data of third parties without authorization.
• •Do not use Ovinchi to store clinical records, legal documentation or other people's secrets.
• •You may delete content from the available features or request its erasure.

Ovinchi uses artificial intelligence systems to combine calculations previously performed by its engines, interpret text and images, answer questions and generate meditations or profiles. Depending on availability and feature, OpenAI, Anthropic and Google Vertex AI/Gemini may be involved. Only the context reasonably necessary to produce the requested result will be sent.

• •Before the first transfer of personal data to an AI provider, Ovinchi will inform of the data categories involved and request explicit permission.
• •Providers act under their contracts and terms for enterprise or API services. Ovinchi does not voluntarily authorize training of general models with the content, unless new information and consent are provided when required.
• •Results are automated, interpretative and may contain errors, omissions or inaccurate information.
• •Ovinchi does not use these profiles to make legal decisions or decisions producing significantly similar effects on the user.
• •Withdrawing permission will prevent new transfers to AI and may disable the features that depend on that processing, without affecting other independent features.

Photographs of the palm and handwriting samples are used to generate the requested interpretations. They are not used to authenticate the user or to uniquely identify them. Even so, they are personal data of particular practical sensitivity and may be subject to automated analysis of traits or patterns.

• •Providing these images is optional.
• •A signature used in banking, administrative or contractual documents should not be sent if it can be avoided; a sample created specifically for Ovinchi is recommended.
• •Images will only be kept for the period stated in the retention section and will be deleted along with the account or upon user request.

When the user records audio to dictate a dream, an entry or a query, the audio may be sent to ElevenLabs to convert it into text. To generate certain meditations, text may be sent to the same provider to obtain audio. Ovinchi uses a Standard plan, so it cannot promise zero retention within ElevenLabs' systems.

• •Ovinchi processes dictation audio transiently and does not intend to keep the original file after receiving the transcription.
• •ElevenLabs may retain requests, responses or logs in accordance with its policy, account configuration and security or moderation needs.
• •Depending on the provider's configuration, certain data may be used to improve its services. Ovinchi will review and limit that option when available.
• •The user can avoid this processing by typing content instead of using the microphone.

Provider information: ElevenLabs Privacy Policy.

Compatibility features may allow entering another person's data, such as name or alias and birth data. The user represents that they are authorized to provide it and will use it only for a personal and legitimate purpose. Ovinchi does not create an account for that person and should not receive unnecessary sensitive information about them.

When applicable under Article 14 of the GDPR, the user must provide that person with basic information about the processing or collaborate with Ovinchi to do so. Ovinchi may remove content that infringes third-party rights.

Ovinchi contractually requires processors to apply guarantees of confidentiality, security, assistance with rights requests, erasure and equivalent protection. Apple, Google or other providers may act as independent controllers for their own services, under their own policies.

Some providers or subprocessors may process data outside the European Economic Area, particularly in the United States. Ovinchi will apply the valid mechanism stated in each provider's contract: an adequacy decision, the EU-U.S. Data Privacy Framework where applicable, Standard Contractual Clauses approved by the European Commission, or other safeguards permitted under the GDPR.

The user may request additional information about the safeguards by writing to ovinchi@ovinchi.com. Merely accepting the terms does not replace the contractual guarantees required for an international transfer.

When there is a legal obligation, litigation, fraud or incident, certain data may be blocked for the period strictly necessary. Once that period ends, it will be irreversibly deleted or anonymized.

When processing depends on consent, Ovinchi will request an affirmative, informed action separated by purpose. Silence, inactivity or a pre-checked box will not be considered consent.

• •Accepting the Terms of Use is independent from confirming that this policy has been read.
• •Permission for AI, especially sensitive data, voice, analytics and marketing communications will be managed separately where applicable.
• •The user may withdraw consent through the available controls or by writing to ovinchi@ovinchi.com.
• •Withdrawal does not affect the lawfulness of prior processing, but may prevent using the feature that needs that data.

The user may exercise the following rights free of charge:

• •Access: to know whether their data is being processed and obtain a copy.
• •Rectification: to correct inaccurate or incomplete data.
• •Erasure: to request deletion where applicable.
• •Objection: to object to processing based on legitimate interest, including certain analytics.
• •Restriction: to request that data be blocked in the legally established cases.
• •Portability: to receive the data provided in a structured format where applicable.
• •Withdrawal of consent and the right not to be subject to automated decisions with legal or similarly significant effects.

The request can be sent to ovinchi@ovinchi.com stating the right exercised. Ovinchi may request information to verify identity without collecting excessive data. It will generally respond within one month, extendable in the cases provided for by the GDPR.

You may also lodge a complaint with the Spanish Data Protection Agency (AEPD), C/ Jorge Juan 6, 28001 Madrid.

The user may request an export of their data. Ovinchi generates a file and sends it to the associated email via Google Gmail. The file may include especially private information, so the user must protect their mailbox and delete copies no longer needed. Google will process the message under its own terms and policy.

Account deletion is requested from within the app. The account is deactivated immediately and, after the ordinary 30-day grace period, account, database, storage and authentication data are purged, except for anonymized, blocked or legally required information.

Ovinchi applies technical and organizational measures proportionate to the risk, such as access control, environment separation, encryption in transit, credential protection, security logging and Firebase access rules. No system is infallible, and the user must also protect their device and credentials.

If a security breach occurs that poses a risk to individuals, Ovinchi will assess the incident, document it and notify the authority and affected individuals when required by law.

Ovinchi may update this policy due to legal, technical or functional changes. Material modifications will be communicated visibly. If a new purpose requires consent, it will be requested before starting the processing. The version, date and effective date will appear at the beginning of the document.

The following links provide additional information about the main providers. They may change without Ovinchi's involvement; the version in force and the contract signed for the relevant service will always apply.