Privacy Policy
Effective date: July 23, 2026
Last updated: July 23, 2026
1. Who We Are
VENORA is a mobile application and associated service providing astrological calculations, reports, personalized content, and social features.
The controller of your personal data is:
Eleventh Industries
UIC: 208645282
37A Marmarliyska Street
Veliko Tarnovo, Bulgaria
Email regarding data protection:
info@eleventhindustries.com
Support email:
info@eleventhindustries.com
Throughout this Privacy Policy, "VENORA", "we", "us", and "our" refer to Eleventh Industries acting as the controller of your personal data.
If we appoint a Data Protection Officer in the future, their contact details will be published here.
2. Scope of this Privacy Policy
This Privacy Policy explains how we process personal data when you:
- create and use a VENORA account;
- sign in using email and password, Google Sign-In, or Sign in with Apple;
- enter birth information;
- request or purchase reports;
- request AI summaries;
- use social features;
- receive notifications;
- contact us;
- exercise your data protection rights;
- delete your account.
This Privacy Policy does not apply to processing activities carried out independently by controllers such as Google, Apple, Google Play, the Apple App Store, or other third-party services when they process personal data under their own privacy policies and for their own purposes.
3. Personal Data We Process
We process personal data that:
- you provide directly;
- we receive from third-party providers at your request;
- is generated while using the application;
- is necessary for security, accounting, or protection of our legal rights.
3.1 Account Information
We may process:
- username;
- name or display name;
- email address;
- preferred language;
- account status;
- registration method;
- account creation and modification timestamps.
If you register using email and password, we do not store your password in plain text. Instead, we store only a secure cryptographic password hash.
3.2 Google and Apple Sign-In Information
If you sign in using Google Sign-In or Sign in with Apple, we may receive:
- external account identifier;
- email address;
- name, where provided;
- confirmation that your identity has been authenticated by the provider;
- login and account-linking timestamps.
We do not receive or store your Google or Apple password.
3.3 Birth Information and Astrological Data
To perform astrological calculations, we may process:
- date of birth;
- time of birth;
- city or place of birth;
- geographic coordinates;
- time zone;
- astrological positions, aspects, houses, zodiac signs, and related calculations;
- generated interpretations;
- grammatical gender where required to generate natural-language text.
3.4 Information About Another Person
VENORA allows you to create reports relating to another individual, such as a partner, friend, or family member.
In these cases we may process:
- report name;
- date, time, and place of birth;
- grammatical gender;
- calculated astrological information;
- compatibility or relationship interpretations.
When you provide information about another person, you are responsible for ensuring that you have an appropriate legal basis or authorization to do so.
If that legal basis no longer exists, you should delete the relevant information or contact us.
If an individual whose information has been entered into VENORA exercises their data protection rights, we will assess the request in accordance with applicable law after verifying identity and considering the rights of all affected individuals.
3.5 Social Features
When you use social features, we may process:
- searched usernames;
- connection requests;
- sender and recipient identifiers;
- connection status;
- timestamps of social interactions;
- limited profile and astrological information displayed according to the connection type.
3.6 Purchases and Paid Services
When you make a purchase, we may process:
- application store;
- product identifier;
- application identifier;
- purchase token, signed transaction, or purchase reference;
- hashed purchase reference;
- order identifier;
- purchase status, confirmation, refund, revocation, or chargeback status;
- purchase timestamp;
- identifiers of associated reports and access rights;
- information indicating whether an AI summary was requested.
We do not process or store payment card information.
Payments are processed through Google Play or the Apple App Store.
3.7 AI Summary Information
If you expressly request an AI summary, we may send a limited portion of the report to our AI provider.
As a general principle, we aim not to transmit:
- names;
- email addresses;
- account identifiers;
- exact birth date, time, or place;
- payment information;
- internal business identifiers where unnecessary.
We may transmit:
- portions of astrological interpretations;
- report structure;
- selected language;
- grammatical gender;
- other minimum information required to generate the requested summary.
3.8 Device, Session, and Security Information
We may process:
- session identifiers;
- device and platform information;
- user agent;
- IP address;
- login, logout, expiration, and renewal timestamps;
- session status;
- security-related events;
- authentication results;
- request and task identifiers.
3.9 Notification Information
If you enable notifications, we may process:
- push notification token;
- platform;
- language and regional preferences;
- notification preferences;
- delivery status;
- timestamp of last activity.
3.10 Support Communications
When you contact us, we may process:
- email address;
- communication contents;
- technical information relating to the communication;
- information required to verify identity and resolve your issue.
3.11 Local Storage on Your Device
The application may store locally on your device:
- session tokens;
- cached profile information;
- application settings;
- temporarily stored report data;
- purchase restoration information.
If you export a report as a PDF or share it through another application, we cannot automatically delete copies stored outside VENORA.
4. Why We Process Personal Data
We process personal data for the following purposes:
- creating and managing accounts;
- authentication and session management;
- performing astrological calculations;
- generating and delivering reports;
- processing and verifying purchases;
- generating AI summaries when requested;
- providing social features;
- sending notifications;
- protecting against fraud, abuse, and unauthorized access;
- providing technical support and diagnostics;
- complying with accounting, tax, and legal obligations.
Processing is limited to specific, explicit, and legitimate purposes and does not exceed what is necessary to achieve those purposes, in accordance with the principles set out in Article 5 of Regulation (EU) 2016/679 (GDPR) and the obligation to implement appropriate measures under Art. 59(1) and (4) of the Bulgarian Personal Data Protection Act (ЗЗЛД).
5. Legal Bases for Processing
We process personal data only where a valid legal basis exists.
5.1 Performance of a Contract
We process personal data where necessary to:
- register and maintain your account;
- authenticate users;
- perform astrological calculations;
- generate requested reports;
- process purchases;
- restore purchased content;
- delete your account upon request.
5.2 Legitimate Interests
We may process personal data for:
- system security;
- fraud prevention;
- account protection;
- maintaining logs and audit records;
- diagnosing technical issues;
- protecting our legal rights and legitimate interests.
We rely on this legal basis only where our legitimate interests are not overridden by your fundamental rights and freedoms.
5.3 Legal Obligation
We process or retain personal data where necessary to:
- comply with accounting and tax obligations;
- respond to lawful requests from competent authorities;
- comply with data protection obligations;
- maintain mandatory commercial records.
5.4 Consent
We rely on consent where processing is genuinely optional, for example:
- certain categories of push notifications;
- marketing communications;
- other optional features where required by applicable law.
You may withdraw your consent at any time.
Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
5.5 Legal Claims
We may process limited personal data where necessary to establish, exercise, or defend legal claims.
6. AI Content
6.1 When AI is Used
AI summaries are generated only if you expressly request them.
6.2 Information Used
Only the minimum information necessary to generate the requested AI summary is provided to the AI service provider.
6.3 Limitations
AI-generated content is automatically generated and may contain inaccuracies, omissions, or interpretations.
It does not constitute medical, psychological, legal, financial, or other professional advice.
6.4 AI Provider
AI summaries are currently generated using OpenAI.
Where we use an external AI provider, we apply data minimization and appropriate contractual safeguards in accordance with Article 28 of Regulation (EU) 2016/679 (GDPR) and Art. 61(3) of the Bulgarian Personal Data Protection Act (ЗЗЛД).
7. Payments and Purchases
Payments are processed through Google Play or the Apple App Store.
We receive only the information necessary to:
- verify purchases;
- provide access to purchased content;
- prevent abuse;
- maintain records and resolve disputes.
We may retain limited purchase information after account deletion where required by law or necessary for the establishment, exercise, or defense of legal claims.
8. Social Features and Visibility
If you use social features, certain information may be visible to other users depending on the connection type.
Before accepting a connection request, you should understand that another user may gain access to certain profile and astrological information as described within the application and this Privacy Policy.
The following information is never shared through social features:
- email address;
- login credentials;
- payment information;
- internal administrative identifiers.
Users may not use social features to impersonate others, harass users, collect information unlawfully, or engage in other unlawful conduct.
9. Who We Share Personal Data With
We do not sell personal data.
We may disclose personal data only where necessary to:
- authentication providers such as Google and Apple;
- payment providers and app stores;
- cloud infrastructure providers;
- push notification providers;
- email service providers;
- geocoding providers;
- AI providers when you request AI functionality;
- competent public authorities where required by law;
- parties involved in corporate restructuring where permitted by law.
Where a third party processes personal data on our behalf, it acts as a processor and is bound by a contract or other legal act in accordance with Art. 61(3) and (4) of the Bulgarian Personal Data Protection Act (ЗЗЛД) and Article 28 of Regulation (EU) 2016/679 (GDPR).
10. International Transfers
Where possible, we use infrastructure located within the European Economic Area.
Where personal data is transferred outside the European Economic Area, we do so only where an appropriate legal transfer mechanism applies, such as:
- an adequacy decision;
- Standard Contractual Clauses;
- another legally recognized safeguard.
You may contact us for additional information regarding these safeguards.
11. Retention Periods
We retain personal data only for as long as necessary for the relevant purpose unless a longer retention period is required by law.
11.1 Account Information
Retained while your account remains active unless longer retention is required by law or for legal claims.
11.2 Purchased Reports
Retained while your account and access to the service remain active unless deletion is requested or longer retention is required for disputes, security, or legal obligations.
11.3 Purchase Records
Purchase records may be retained for up to 10 years where required by applicable accounting or tax legislation.
11.4 Logs and Security Records
- Operational logs: up to 30 days.
- Security audit records: up to 365 days.
Longer retention may occur where necessary for incident investigations, legal obligations, or legal claims.
11.5 Support Communications
Support communications are retained only for the period reasonably necessary to resolve the issue, maintain records, and protect legal interests.
11.6 Information Stored on Your Device
Files stored locally or exported by you remain under your control and may continue to exist outside our systems.
12. Account Deletion
You may request deletion of your account through the application or by contacting us.
Following a valid request, we will:
- terminate access to your account;
- delete or anonymize personal data where applicable;
- retain only information required by law or necessary for security, accounting, fraud prevention, or legal protection.
Deleting your account does not delete reports or files you have exported outside VENORA.
13. Security
We implement technical and organizational measures designed to protect personal data, including where appropriate:
- TLS/HTTPS communication;
- access controls;
- session and token protection;
- password hashing;
- logging and audit records;
- role-based access restrictions;
- fraud prevention measures;
- periodic review and updating of security measures.
These measures are implemented in accordance with the obligation to ensure an appropriate level of security under Art. 59(1)–(4) of the Bulgarian Personal Data Protection Act (ЗЗЛД) and Article 32 of Regulation (EU) 2016/679 (GDPR).
No system is absolutely secure.
If you believe your account has been compromised, please contact us immediately.
14. Personal Data Breaches
If we become aware of a personal data breach, we will act in accordance with applicable law.
Where required, we will document the breach, notify the competent supervisory authority without undue delay and, where applicable, no later than 72 hours after becoming aware of it, and notify affected individuals where required by law, in accordance with Art. 67(1), (3), and (5) of the Bulgarian Personal Data Protection Act (ЗЗЛД).
15. Your Rights
Subject to applicable law, you have the right to:
- access your personal data;
- correct inaccurate information;
- request deletion;
- request restriction of processing;
- object to certain processing;
- request data portability where applicable;
- withdraw consent where processing is based on consent;
- lodge a complaint with a supervisory authority.
To exercise your rights, contact:
info@eleventhindustries.com
We may request reasonable information to verify your identity.
As a general rule, we respond to requests without undue delay and no later than one month after receiving them. Where necessary, this period may be extended in accordance with applicable law, and we will inform you of the extension.
The requirements concerning transparent information and the exercise of data protection rights arise from Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR) and Art. 54(1) and (2) of the Bulgarian Personal Data Protection Act (ЗЗЛД).
If you believe your rights have been violated, you may lodge a complaint with the Bulgarian Commission for Personal Data Protection or another competent supervisory authority.
16. Children
VENORA is not intended for individuals under the age of 14.
Individuals below this age may not create an account unless permitted by applicable law and all legal requirements have been satisfied.
If we determine that personal data has been collected in violation of applicable law, we will take reasonable steps to delete it.
Where users enter information relating to another individual, including a child, they are responsible for ensuring that they have an appropriate legal basis for doing so.
17. Changes to this Privacy Policy
We may periodically update this Privacy Policy to reflect:
- changes to the Services;
- new features;
- new providers;
- changes in legislation;
- changes to security measures.
Where material changes are made, we will update the "Last updated" date and, where required by law, notify users appropriately before the changes take effect.
18. Contact
For questions regarding this Privacy Policy or to exercise your rights, please contact:
Eleventh Industries
37A Marmarliyska Street
Veliko Tarnovo, Bulgaria
Email: info@eleventhindustries.com