Consent to processing of special categories of personal data in the Lunar Oracle

Edition 5 of 25 September 2026. A separate document because the basis is separate: data concerning health and data concerning your sex life are special categories under GDPR Art. 9, and processing them requires your explicit consent (Art. 9(2)(a)). Accepted together with the two other Lunar Oracle documents by a single tick on the consent screen; the box is not pre-ticked.

1. Controller

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.

2. Which data, and where it comes from

• Cycle: cycle phase and day, interval history, delays, the start date of your last period, the text of today's recommendation. Source — what you record yourself in the app.
• Body signals from Apple Health: sleep, heart rate variability, resting heart rate, wrist temperature during sleep, cycle symptoms. They are computed on your phone, travel only with the message you sent, and are not stored on our servers. They are sent only if you allowed the iPhone app to read them in the Apple Health system prompt, which appears once after you give consent; declining that prompt closes nothing, and access is revoked in the iPhone settings. What reaches the Oracle is a comparison against your own usual picture, not an instrument reading.
• Intimacy marks you place in the calendar — data concerning your sex life.

Menstrual flow is not part of this list. It syncs with the calendar separately, in Apple Health settings, is stored on the server, and is not governed by this consent.

3. What happens to it

It is collected, used to produce the Lunar Oracle's reply, and transferred together with your message to the recipients listed below: to the primary one — kie.ai with the DeepSeek model — or, when it is unavailable, to the reserve, Google. The controller passes it to them 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; their terms are set out here as well. DeepSeek's terms do not describe whether data received is used for training, so the controller assumes that DeepSeek may use it — including this data concerning health and sex life — to train its models, and this cannot be opted out of through the app. The transfer out of your country, including possibly to the People's Republic of China, is covered by a separate consent.

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.

• NEXUSAI SERVICES LLC (kie.ai) — the kie.ai API aggregator: receives the request, processes it with the DeepSeek model and returns the reply. Address: 118 Krameria St, Denver, CO 80220, USA. Country of processing: the United States of America — kie.ai does not disclose where exactly the model runs; by its public statements, on servers in the USA. Training on data: the kie.ai privacy policy does not say whether the content of API requests is used to train models. Retention: not disclosed — the kie.ai privacy policy does not state how long request content is kept. Data processing agreement: not confirmed — we have no separate agreement with kie.ai. Capacity: if it uses the data beyond relaying it to the model, it processes it for its own purposes as an independent controller, not on the controller's behalf; there is no contract with kie.ai.
• Hangzhou DeepSeek Artificial Intelligence Co., Ltd. (DeepSeek) — developer of the DeepSeek model that writes the primary recipient's reply; a possible recipient: kie.ai does not disclose where exactly the model runs, and it cannot be ruled out that request content is passed to DeepSeek in the PRC, so the controller assumes the worst case. Address: Room 1201, Building West 1, Huijin International Mansion, No. 169 Huancheng North Road, Gongshu District, Hangzhou, Zhejiang, People's Republic of China. Country of processing: possibly the People's Republic of China — if request content is passed to DeepSeek. Training on data: DeepSeek's Open Platform terms do not describe the use of data received for training; the controller assumes that DeepSeek may use it to train its models, and this cannot be opted out of through the app. Retention: not disclosed — DeepSeek's Open Platform terms do not describe how long data is kept. Data processing agreement: not confirmed — we have no separate agreement with DeepSeek. Capacity: may process the data it receives for its own purposes as an independent controller, not only on the controller's behalf; there is no contract with DeepSeek.
• Google LLC (Google) — owner of the Gemini model that writes the reply (paid Gemini API tier). Address: 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Country of processing: the United States of America and any other country where Google operates capacity: Google processes and may temporarily cache data wherever its infrastructure runs. Training on data: under the paid Gemini API terms Google does not use prompts and replies to train models or improve its products, and does not have them reviewed by people for that purpose. Retention: prompts and replies are logged for a limited period — solely to detect policy violations and for legally required disclosures. Data processing agreement: confirmed by the controller on 19 September 2026 (Gemini API Paid Services terms). Capacity: processes the data on the controller's behalf under the paid Gemini API terms.

The history of this list is on the AI recipients page.

4. Purpose

So the reply speaks to you rather than in general: it leans on where you are in your cycle and how you slept, not on generic words. The controller processes it not for advertising, not for profiling and not for medical conclusions. The Lunar Oracle is not a doctor and makes no diagnoses.

5. Where this data never ends up

• your full date and time of birth;
• e-mail;
• phone number;
• payment details.

The conversation is not stored on our servers — it lives only on your device.

6. Duration and withdrawal

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 processing; what has already left cannot be recalled — including where a recipient has already used it to train its model. You can erase all your data entirely in the same place, in account settings. 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 special categories of data in the Lunar Oracle only.