TuningSoul
Privacy Policy of TuningSoul
Last updated: [to be completed]
TuningSoul is an application published by Ciral Studio, established in France. For any request, you may use the contact form.
This policy explains what data is used in the application, for what purposes, for how long, and what your rights are.
1. Data used
TuningSoul may use the following data:
- account information, such as the email address or identifiers required for login;
- birth information that you choose to provide, such as date, time and place of birth;
- data related to your use of the application, such as your cycle, preferences or subscription status;
- the content of your journal;
- certain technical data necessary for the operation, security and diagnosis of the application.
2. Why this data is used
This data is used to:
- create and manage your account;
- calculate and display your personal cycle;
- provide symbolic readings, rituals, correspondences and application content;
- manage your TuningSoul Premium subscription;
- ensure the proper operation, security and improvement of the service;
- respond to your support requests.
3. Legal bases
TuningSoul’s data processing is based, depending on the case:
- on the performance of the requested service when the data is necessary for the operation of the application and the subscription;
- on compliance with legal obligations where required by law;
- on the legitimate interest of Ciral Studio for security, maintenance and improvement of the service;
- and, where necessary, on your consent.
The CNIL recalls that data processing must always be based on a valid legal basis, such as the performance of a contract, a legal obligation, legitimate interest or consent.
4. Private journal
The TuningSoul journal is designed as a private space.
Its content is encrypted. In the normal operation of the service, Ciral Studio cannot read your journal in plain text. In practice, only encrypted content is stored on the server side.
Journal content is not used for advertising, commercial or profiling purposes.
5. Data recipients
Your data may be processed, to the extent necessary, by:
- Ciral Studio, as publisher of the application;
- Supabase, used for database hosting, authentication and content storage;
- RevenueCat, used to manage subscriptions and their status within the application.
To date, no analytics or crash reporting tool is used.
6. Subscriptions and purchases
Payments made in the application are processed by Apple through the App Store.
Ciral Studio does not have access to your full banking information.
7. Retention periods
Data is not kept indefinitely. The CNIL recalls that a retention period must be defined according to the purpose pursued.
For TuningSoul:
- active data related to your account is retained as long as your account remains active;
- if you request deletion of your account, active data is deleted as soon as possible;
- technical backups may be retained temporarily, for a maximum period of 90 days;
- technical logs strictly necessary for security and proper operation of the service may be retained for up to 6 months; the CNIL recommends a rolling retention period of approximately six months to one year for certain security logs.
8. Account deletion
You may request deletion of your account directly from within the application.
Apple requires applications that allow account creation to also allow users to initiate account deletion within the app, and specifies that deletion must remove the account and associated data that is not legally required to be retained.
9. Your rights
In accordance with the GDPR, you have in particular the following rights:
- right of access;
- right to rectification;
- right to erasure;
- right to restriction of processing;
- right to object;
- right to data portability, where applicable.
The CNIL recalls that individuals must be informed of these rights and be able to exercise them.
You may exercise your rights through the contact form.
If, after contacting us, you believe that your rights are not being respected, you may also file a complaint with the CNIL.
10. Security
Ciral Studio implements appropriate technical and organizational measures to protect the personal data processed in TuningSoul.
This includes in particular:
- access limitation;
- protection of exchanges;
- technical logging;
- and, for certain data such as the journal, encryption.
The CNIL recommends in particular securing access, logging certain security operations and using encryption where relevant.
11. Transfers outside the European Union
The main data of the application is hosted in the European Union through Supabase, in the West EU (Ireland) eu-west-1 region.
However, certain subscription-related data may be processed by RevenueCat, whose infrastructure is located in the United States.
Where data is processed outside the European Union, such processing is governed by the appropriate safeguards provided for by the applicable regulations.
12. Changes
This policy may be updated to reflect changes in the application, the services used or legal obligations.
The version displayed in the application is the version in force.
13. Contact
For any question relating to this Privacy Policy, you may contact Ciral Studio through the contact form.