Privacy Policy — Cleoda Labs

Last updated: 2026-03-20

This policy explains what data we collect when you use our website and apps (AstroBani, FinAstro, Ulciorul cu Litere, Calendar Ortodox, Moara, Ten Frames, Pro 101 Modeling Poses), how we use it, and what rights you have.

Who we are

Cleoda Labs
Email: contact@cleodalabs.com

What data we collect

• Account data (name, email) when you subscribe or contact us.
• Payment data (processed by third parties, e.g., Stripe) — we do not store card numbers.
• Technical data (IP, device) for security and fraud prevention.
• Aggregated analytics (no profiling), if enabled.

Legal bases (GDPR/UK GDPR)

• Contract performance (subscriptions and service access).
• Legitimate interest (security, fraud prevention, service improvement).
• Consent (newsletters, non-essential cookies).

Processors

• Stripe (payments, SCA/PSD2).
• Apple/Google (if you purchase in-app).
• Email/hosting providers (e.g., Vercel, Resend).

International transfers

We may process data outside UK/EEA using appropriate safeguards (SCCs).

Retention

We keep data as long as necessary (legal, accounting, support).

Your rights

Access, rectification, deletion, objection, portability, withdrawal of consent. Write to us at contact@cleodalabs.com.

App-specific sections

AstroBani

• Data: account, subscription, preferences.
• Payments: Stripe; recommended descriptor: *CLEODALABS ASTROBANI*.

FinAstro

• Data: account, calendar settings, subscription.
• Payments: Stripe.

Ulciorul cu Litere

• Children's product: no personalized advertising, no profiling.
• Data stored locally on device only (game progress, preferences). No account creation required. No personal data transmitted to any server.
• Advertising: Google AdMob displays non-personalized ads only (child-directed treatment enabled). AdMob may collect device identifiers and IP address per Google's privacy policy; no behavioral profiling is performed.
• In-app purchase: Apple App Store (remove ads). Purchase data is handled entirely by Apple; we do not store payment information.
• No data is shared with third parties beyond AdMob and Apple.

Calendar Ortodox

• Data: account, reminders, subscription (if applicable).

Moara - Nine Men's Morris

• Data: game preferences (piece skin, board skin, language, sound settings) stored locally on your device.
• No account or personal data is collected.
• Advertising: Google AdMob displays banner ads. AdMob may collect device identifiers, IP address, and ad interaction data per Google's privacy policy.
• In-app purchases: Google Play Billing (remove ads). Purchase data is handled by Google; we do not store payment information.
• No data is shared with third parties beyond AdMob and Google Play.

Pro 101 Modeling Poses

• Fully offline application: no data is transmitted to any server or third party.
• No account creation required. No personal data is collected.
• Data stored locally on device only: favorites list and onboarding status, using UserDefaults.
• No analytics, no tracking, no advertising, no profiling.
• In-app purchase: Apple App Store (unlock all poses). Purchase data is handled entirely by Apple; we do not store payment information.
• PDF release forms are templates only — any personal data entered on printed forms is the sole responsibility of the user.
• No third-party SDKs or libraries are used.

Ten Frames - Matematica cu Zâmbete

• Children's product (ages 6-7): no personalized advertising, no profiling, no analytics.
• Data stored locally on device only (player name, theme preference, language, game progress) using AsyncStorage.
• No data is transmitted to any server or third party.
• No account creation required.
• Optional in-app purchase (Google Play Billing) to unlock premium features. Purchase data is handled by Google; we do not store payment information.
• Fully COPPA-compliant: no personal data collection from children.

DPO Contact

contact@cleodalabs.com