Personal Data Processing Consent

1. General Provisions

This Consent for Personal Data Processing (hereinafter the "Consent") is granted by the User to the Operator in accordance with Federal Law of the Russian Federation No. 152-FZ dated 27 July 2006 "On Personal Data" for the purposes set out in the Sky Celestial public offer.

Consent is granted freely, by the User’s will and in the User’s interest. It is effective from the moment of acceptance (registration on the platform or payment for any service) and until withdrawn by the User in the manner provided herein.

2. Personal Data Operator

The Operator processing personal data is:

3. Processing Purposes

The Operator processes personal data for the following purposes:

• Provision of astrological information and entertainment services (natal chart calculation, horoscopes, AI consultations, compatibility analysis)
• User identification and providing access to the personal dashboard
• Payment processing and performance of contractual obligations, including recording consent to recurring debits
• Provision of technical support and responding to User requests
• Sending marketing and informational newsletters subject to the User’s explicit separate consent (checkbox at registration or in settings)
• Compliance with the laws of the Russian Federation

4. Categories of Processed Data

4.1. Registration Data

• Name or pseudonym, email address
• Birth date, birth time, and birth location (used solely for astrological calculations on the Sky Celestial side and never sent to external AI services in raw form)
• Gender (if provided by the User)

4.2. Technical Data

• IP address, browser User-Agent
• Cookies, session identifiers, data on activity within the platform

4.3. Payment Data

Payment details (bank card number, CVV, expiry date) are processed directly by the payment operators Robokassa and NowPayments. Sky Celestial neither receives nor stores card numbers; the platform stores only the binding identifier (token) for recurring payments, transaction status, and amount.

4.4. Recurring Payment Consent Records

To evidence voluntary consent to automatic debits, the following are recorded: IP address, User-Agent, public offer version, and timestamp of the consent.

5. Processing Methods

Personal data processing is performed both with and without automated means and includes the following actions:

• Collection, recording, systematisation, accumulation, storage
• Updating and modification
• Retrieval and use
• Transfer (only in anonymised aggregated form or to the payment operators Robokassa / NowPayments to the extent necessary to complete a transaction)
• Anonymisation, blocking, deletion

6. Retention Period

• Registration and technical data are retained until the User withdraws this Consent or the Operator ceases operations
• Payment records are retained for 5 (five) years in accordance with the Tax Code of the Russian Federation
• Records of consent to recurring payments (IP, UA, offer version, timestamp) are retained for the entire subscription term and for 3 (three) years after termination to address potential disputes and chargebacks

7. Disclosure to Third Parties

Personal data may be transferred to the following counterparties only to the extent and for the purposes specified below:

• Robokassa, NowPayments: payment processing and recurring debits (transferred: subscription identifier, amount, email for receipt delivery)
• OpenAI: AI consultation request processing exclusively in anonymised form (without name, exact birth date/time/location, or coordinates)

Personal data is neither transferred nor sold to third-party brands or advertising networks for targeted advertising purposes.

8. Rights of the Data Subject

In accordance with Federal Law 152-FZ, the User has the following rights:

• Withdraw this Consent at any time by sending a written request to legal@sky-celestial.ru
• Request rectification, blocking, or deletion of personal data if it is inaccurate or outdated
• Receive information about the categories of processed data and the purposes of processing
• Appeal the Operator’s actions or omissions to the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) or in court

Withdrawal of Consent results in termination of paid Platform services and deletion of the account within 30 (thirty) calendar days, except for data subject to mandatory retention by law.

9. Security Measures

The Operator applies legal, organisational, and technical measures to ensure the security of personal data in accordance with Federal Law 152-FZ and related regulations:

• Encryption of data transmission via TLS 1.3
• Encryption of sensitive data at rest
• Role-based access control (RBAC) and the principle of least privilege
• Audit logging of all personal data operations
• Regular backups and disaster-recovery testing
• Sanitisation (PII-sanitizer) of data prior to transfer to external AI services

10. Operator Details