Privacy Policy (draft)

2026-11-draft-3

DRAFT. This text is a working draft and must be reviewed by a lawyer before publication.

1. Who is responsible

RENVAR INC., 350 Bay Street, Suite 1300b, Toronto, ON M5H 2S6, Canada (Ontario Corporation Number 1001508737) ("RENVAR", "we") runs Lilit and decides how your personal data is used. Contact for privacy questions and requests: renvar.inc@proton.me.

2. What we collect

Things you give us:

Account: email address and password (we do not see your password in clear text).
Your profile: name, date, time and place of birth, country, language, favourite master and settings. The profile is kept on your device.
Your location, only if you allow it, to show the sky above you and to calculate sunrise, sunset and planetary hours. It is used on your device for calculations.
Notes, dreams, diary entries, friends, clients, events and other things you write. They are kept on your device in an encrypted store.
Information about other people that you enter, for example a friend, a client, or your child in the Family section. Please enter it only if you have the right to do so. Family data stays on your device and is not sent to our servers or to AI providers.
Your questions to the masters and their answers. The last messages are kept on your device.
Palm photos, only if you choose to analyse one and give a separate consent (see section 5).
Messages you send to support.
Reports you send about an AI answer: the reason, your optional comment, the reported answer and the question before it; the team reviews them to improve safety and keeps them up to 365 days.
Your consent record: your full name as you typed it, the version of the documents, date and time, country, language and platform.

Things we collect automatically:

Usage events: a random device identifier (not your name), session, pages or screens, language, app version and similar technical information. The website does not use cookies or a persistent identifier.
Technical data such as IP address in server and sign-in logs, used for security and abuse prevention.
Payment data: the product, amount, date and status of a payment, and a card label such as "Visa •••• 4567" for website payments. We never receive your full card number. Purchases in the iOS app are handled by Apple; we receive confirmation of the purchase and its dates.
Crash reports: if the app crashes, a technical report is sent to our crash-reporting provider: error type, stack trace, device model, system and app versions and a random device identifier. It contains no names, emails, texts of your questions, photos or location.

3. Why we use it, and on what basis

To calculate your chart, transits and forecasts and to write texts in your language: to provide the Service you asked for (contract).
To run your account, support, payments and access to paid features (contract and legal obligations).
To remind you at the time you choose (your consent, which you can withdraw in the device settings).
To keep the Service safe, prevent abuse and fix errors, and to understand which features are used with anonymous statistics (our legitimate interests).
To keep a proof of your consent to our documents (legal obligation and legitimate interests).

We do not sell your personal data and we do not use it for advertising. We do not use advertising trackers.

4. AI processing

When you ask a master a question, we send to our AI provider the text of the question, the last few messages of the conversation, your first name, facts calculated from your chart (for example signs and houses), the date and your language and country, and master notes if you turned the master's memory on. We do not send your exact date, time or place of birth. AI providers process this data on our behalf to produce the answer. Under their current API terms they may keep requests for a limited period for operation and safety and do not use them to train their models by default; please see their terms. We use Anthropic as our main AI provider and OpenAI as a backup.

Before the first request to an AI service the app asks for your explicit permission, and shows what is sent and to whom. Without your permission nothing is sent to AI providers: the AI masters do not answer, the master's reply is not sent for voice, and master notes are not sent. You can withdraw the permission at any time in Settings, section "Data and AI"; after that nothing more is sent. Data that the providers have already processed is handled under their terms described above.

5. Photos

A palm photo is sent for analysis only after your separate consent. The photo is processed in memory by the AI provider that describes what is visible, it is not saved on our servers, and only the text result stays on your device. We do not use photos to identify anyone, do not create biometric templates, and do not use photos to train AI models. Please send only your own hand, and only if you are an adult. You can delete all results in the app at any time.

6. Voice

Lilit does not record or store your voice. When you speak, your device (or browser) converts speech to text with its own speech recognition, on the device where it is available, otherwise by the system service of Apple or Google. Only the text is sent to us. The master's answer may be read aloud with a voice service (Cartesia), which receives the sentences of the answer to turn them into sound. This happens on the website and, for signed-in users, in the app, and only if you have allowed data sharing with AI services; otherwise your device's own voice reads the answer.

7. Who else handles data

We use service providers who process data on our behalf:

Supabase: database, account sign-in, support and usage records (servers in London, United Kingdom).
Railway: hosting of our server and website.
Anthropic and OpenAI: AI answers (section 4).
Cartesia: voice of the masters' answers (section 6).
Sentry: crash reports from the mobile app.
Payment providers: YooKassa for website payments in some countries; Apple, Google Play (App Store) and RevenueCat (subscription management) for purchases in the iOS app.
An email service for account emails such as email confirmation and password reset.
Place search: when you type a place, the text of the place name is sent to a geocoding service (Photon / OpenStreetMap data or Open-Meteo) to find coordinates.
Telegram: if you talk to our Telegram bot, Telegram processes the conversation; our team may also receive internal alerts that contain your email address, for example about a new support message.

We may also share data when the law requires it or to protect rights and safety. We do not share your data with advertisers.

8. Transfers between countries

RENVAR is in Canada, our main servers are in the United Kingdom, and some providers are in the United States and other countries. Your data may therefore be processed outside your country. Where the law requires it, we use appropriate safeguards for such transfers.

9. How long we keep it

Data on your device stays there until you delete it or remove the app. The last 80 chat messages are kept; master notes expire after 180 days unless you pin them.
Account, support messages and subscription data are kept until you delete your account.
Usage events are kept for up to 400 days. Daily question counters for about 7 days.
Payment records are kept in anonymised form after you delete your account, as long as the law requires.
The consent record is kept as proof of your consent for as long as the law allows or requires.
Security and sign-in logs are kept as long as needed for security.

10. Your rights and choices

You can, in the app: export your data (Settings, My data), correct it, delete the data on your device, delete your account together with its data on our servers, turn the master's memory off, delete all palm results, cancel a subscription, and withdraw your permission to share data with AI services at any time (Settings, section "Data and AI").

Depending on where you live you may also have the right to access, correct, delete, restrict or object to the use of your data, to withdraw consent, to receive a copy of your data, and to complain to your data protection authority (in Canada, the Office of the Privacy Commissioner). Write to renvar.inc@proton.me; we will answer within 30 days.

11. Children

Lilit is not intended for children. We do not knowingly collect data directly from children. The Family section is for a parent or guardian: the child's data you enter stays on your device, is not sent to our servers and is not used by the AI. If you believe a child has given us data, write to us and we will delete it.

12. Security

Data is sent over encrypted connections. Sensitive data on your device (for example dreams, clients, friends and master notes) is stored encrypted, and you can protect the most private sections with Face ID or a passcode (this is done by your device; we do not receive your biometric data). No system is perfectly secure; please use a strong password.

13. Changes and contact

We may update this policy. The version you accepted is saved with your account. Questions and requests: renvar.inc@proton.me, RENVAR INC., 350 Bay Street, Suite 1300b, Toronto, ON M5H 2S6, Canada (Ontario Corporation Number 1001508737).