Edition 5 of 25 September 2026. A separate document because the transfer rests on its own legal basis: GDPR Chapter V governs transfers to a third country, and where no adequacy decision applies the transfer is made on your explicit consent (Art. 49(1)(a)). Accepted together with the two other Lunar Oracle documents by a single tick on the consent screen; the box is not pre-ticked.
Controller: PT. TECHNO CAPITAL INDONESIA.
Registered address: Jalan Sunset Road No. 99D, Desa/Kelurahan Kuta, Kec. Kuta, Kab. Badung, Provinsi Bali, 80361, Indonesia.
Tax identification number (NPWP): 40.174.113.7-905.000.
Contact for data protection matters — e-mail: [email protected], Telegram: @lunnaya_care, or by post to the registered address above.
The recipients are named below with their names, addresses and the terms on which they process the data. The primary recipient is kie.ai with the DeepSeek model; Google is the reserve, used when the primary is unavailable. The controller passes the data only to produce the reply. There is no data processing contract with kie.ai or DeepSeek, so they may process the data they receive for their own purposes as independent controllers; what each of them may do with the data is governed by its own terms, set out for each.
Recipients as of edition 5 (2026-09-25): primary recipient — kie.ai → DeepSeek; reserve, used when the primary is unavailable — Google. Within this list and on these terms the model provider may change without a new consent; a new recipient or new processing terms require a new consent.
The history of this list is on the AI recipients page.
The legal bases differ by recipient. For Google LLC the transfer relies on the EU-US Data Privacy Framework, under which Google LLC is certified. For kie.ai and DeepSeek there is no adequacy decision and no standard contractual clauses or data processing agreement, so the transfer to them rests on your explicit consent under Art. 49(1)(a), given after being informed of these risks. The level of protection there may differ from the one you are used to, and your ability to enforce your rights abroad may be more limited.
Exactly what the main Lunar Oracle consent and the special-categories consent list: the text of your message, the reply, the recent turns of the conversation, the personalising context, the positions of your natal chart and, when you yourself ask for a reading, further calculations on it, and cycle data, body signals from Apple Health (if you allowed the app to read them) and intimacy marks — all covered by the same indivisible consent. There is deliberately no separate list here: two lists of the same thing drift apart.
To produce the Lunar Oracle's reply to your message. The controller does not transfer the data for advertising or profiling. Please note: DeepSeek's Open Platform terms describe neither how long data is kept nor whether data received is used for training, so the controller assumes that DeepSeek may use it to train its models, and this cannot be opted out of through the app; kie.ai likewise does not disclose how long it keeps request content or whether it is used for training. If you do not accept this, do not give this consent.
The transfer to kie.ai and DeepSeek, made on explicit consent under Art. 49(1)(a), is not backed by an adequacy decision or by standard contractual clauses. Public authorities in the recipient country may have powers of access that the controller cannot refuse; in the People's Republic of China the authorities may require companies to give them access to the data they hold. Neither DeepSeek nor kie.ai has signed a data processing agreement with the controller; they may process the data for their own purposes as independent controllers, and their obligations to you are limited to their own published terms.
This consent lasts while you use the Lunar Oracle and ends when you withdraw it: Settings → Consents (in the iPhone app and in the web app). Withdrawal closes the Lunar Oracle — the consent is indivisible — and touches nothing else: cycle, moon, recommendations and calendar keep working exactly as before. Withdrawal applies to future transfers; what has already left cannot be recalled — including where a recipient has already used it to train its model. You also have the right to lodge a complaint with a supervisory authority — in the EU/EEA, in the member state of your habitual residence, place of work or place of the alleged infringement (GDPR Art. 77); in the United Kingdom, with the Information Commissioner's Office.
The full description of processing is in the privacy policy. This document covers the international transfer only.