NUMIRA – PRIVACY POLICY

Last Updated: July 12, 2026

Croncode LLC ("Croncode," "we," "us," or "our") operates Numira, a numerology-based personal decision-coaching mobile application (the "App" or "Service"). This Privacy Policy explains what personal information we collect, how we use and share it, the choices you have, and how you can exercise your rights.

This Policy applies to the Numira App and any related websites, and to the shared sign-on relationship between Numira and Croncode's companion app, Time Capsule, described in Section 6.

Numira is a decision-support and self-reflection tool. It does not predict the future, provide professional advice, or guarantee outcomes. This Policy should be read together with our [[Terms of Use URL]].

1. Information We Collect

1.1 Information you provide directly

• Account information: email address, and authentication data if you sign in with Apple or another supported provider.
• Profile inputs (about you): your full name and date of birth, which we use to calculate your numerology profile (Life Path, Expression, Soul Urge, and related figures).
• Decision inputs: the free-text description of the two options you enter into the Decision Engine (for example, details about a job offer, a move, or a relationship decision).
• Third-party subject inputs: if you use the Decision Compatibility feature, the name and date of birth of another person you choose to include (for example, a partner or co-founder). By submitting this information you confirm you have that person's permission to do so — see Section 1.2 and our Terms of Use.
• Purchase and subscription data: subscription status, purchased credits, and transaction identifiers provided to us by Apple. We do not receive or store your card details — Apple processes all payments.
• Support communications: anything you send us when you contact support.

1.2 A note on third-party subject data

Decision Compatibility processes personal information about someone other than you. You represent that you have the right to share that person's name and date of birth with us for this purpose and that you have informed them their information will be used to generate a numerology-based compatibility reading. We do not independently verify this. This data is used only to generate your requested output and is subject to the same handling described in this Policy.

1.3 Information collected automatically

• Device and usage data: device type, operating system version, app version, language settings, crash logs, and general usage analytics (for example, which screens you visit and which features you use).
• Approximate location: we do not collect precise (GPS-level) location. We may infer a coarse region (for example, country) from your device or app-store storefront for localization and pricing.

We do not use your data to track you across other companies' apps or websites, and we do not share your information with advertising networks or data brokers.

2. How We Use Your Information

• To generate your numerology profile and personalized, AI-assisted decision analyses and reports.
• To create and administer your account, subscriptions, and credit balance.
• To operate shared sign-on across Croncode applications (Section 6).
• To operate, maintain, and improve the App, including debugging, quality assurance, and analytics.
• To moderate free-text content submitted to the Decision Engine (Section 3).
• To communicate with you about your account, purchases, and material changes to the Service.
• To detect, prevent, and address fraud, abuse, and security incidents.
• To comply with legal obligations.

3. AI Processing Disclosure

Numira's numerology analyses, decision comparisons, and written reports are generated with the assistance of a third-party artificial intelligence service, currently [[AI PROVIDER LEGAL NAME]]. This content is automatically generated and is not written or reviewed by a human before it reaches you.

• When you request an analysis, we transmit only the inputs required to generate it — typically your name, date of birth, decision text, and (if applicable) a third party's name and date of birth — to our AI provider, solely to generate your content.
• Our agreement with our AI provider [[confirm: DOES / DOES NOT]] permit use of your inputs to train their models. [[Verify against the provider's Data Processing Agreement (DPA) before publishing.]]
• We do not send your email address, payment information, or precise location to our AI provider.
• AI-generated content may contain inaccuracies and reflects a structured interpretation of numerological data, not a factual prediction. It is provided for self-reflection and decision-support purposes only.
• Content moderation filters are applied to free-text inputs before and after AI processing (Section 3, Terms of Use).

If a feature within Numira uses a conversational, persona-driven interface, we will separately provide the clear, conspicuous "this is AI, not a human" disclosure required for that interaction format. [[Confirm whether any current or planned feature meets the definition of a "companion chatbot" under Cal. SB 243; if so, additional disclosure and safety-protocol obligations apply.]]

4. Categories of Personal Information Disclosed to Service Providers

In the preceding 12 months, we have disclosed the following categories of personal information to the following categories of recipients, solely for the business purposes described below. We do not sell or share (as those terms are defined under the CCPA/CPRA) your personal information, and we do not disclose it in exchange for money.

Category	Examples	Shared With	Purpose
Identifiers (name, email, device ID)	Name, email address, device/advertising identifiers where applicable	Cloud hosting & infrastructure provider	App hosting, storage, and delivery
Profile & decision inputs	Date of birth, decision text, third-party subject data	AI service provider	Generating your numerology analysis and reports
Purchase data	Subscription status, credit balance, transaction IDs	Apple (App Store)	Payment processing, subscription management, refunds
Usage & diagnostic data	Crash logs, feature usage, app version	Analytics / crash-reporting provider	Reliability, debugging, product improvement
Support communications	Messages you send us, related account details	Customer support tooling provider	Responding to your requests

Current service providers: [[LIST vendor names — e.g., cloud host, analytics/crash tool, AI provider, support desk]].

5. How We Share Information

We share information only in the following circumstances:

• Service providers: as described in Section 4, under contractual confidentiality and data-protection obligations.
• Apple: for payment processing, subscription management, and refunds.
• Croncode ecosystem: your Croncode account identifier (not your Numira profile content) is shared across Croncode apps solely to operate shared sign-on — see Section 6.
• Legal & safety: when required by law, legal process, or to protect the rights, safety, and property of Croncode, our users, or others.
• Corporate transactions: in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy.

We do not sell your personal information and have not done so in the preceding 12 months.

6. Croncode Ecosystem & Shared Sign-On

Numira uses a shared Croncode account so you can move between Numira and Time Capsule without creating a separate account. Your Croncode account identifier and authentication data are shared between apps for this purpose. Numira profile content (your numerology inputs, decision history, and reports) is not shared with Time Capsule except where a specific cross-app feature explicitly says so and you take an action to trigger it (for example, initiating a Time Capsule entry from within Numira).

7. International Data Transfers

Croncode is a U.S. company and our infrastructure and service providers, including our AI provider, are primarily located in the United States. This means personal information from users located outside the United States, including Turkey, is transferred to and processed in the United States.

7.1 Users in Turkey (KVKK)

Under Law No. 6698 (KVKK), Article 9, as amended by Law No. 7499, cross-border transfers of personal data follow a tiered framework rather than relying on consent alone for routine, systematic transfers: (i) transfer to a country, sector, or organization covered by an adequacy decision of the Personal Data Protection Board ("Kurul"); or, absent that, (ii) transfer under an appropriate safeguard, such as a Standard Contract between Croncode and the recipient, filed with the Kurul within five business days of signature; or (iii) in limited, non-systematic ("arizi") cases, one of the exceptional bases listed in Article 9, which may include your explicit consent.

[[This section must be finalized with Turkish counsel before publication.]] Because Numira sends profile and decision data to our AI provider on a routine, recurring basis for every analysis you request, this is unlikely to qualify as an "arizi"/occasional transfer, meaning an adequacy decision or a Standard Contract (rather than a consent checkbox alone) is likely the applicable basis. [[Confirm current adequacy-decision status for the U.S. with counsel; if none applies, execute the Kurul-published Standard Contract with the AI provider and other recipients handling Turkish users' data, and complete the 5-business-day notification to the Kurul.]]

7.2 Users in the United States and elsewhere

For users outside Turkey, we rely on the safeguards described in this Policy and our contracts with service providers to protect your information wherever it is processed.

8. Data Retention

We retain personal information for as long as your account is active and for a reasonable period afterward to comply with legal obligations, resolve disputes, and enforce our agreements. [[Confirm exact retention periods, e.g., account data for X days after deletion request; transaction records for X years per tax/accounting requirements.]] You may request deletion at any time as described in Section 9.

9. Your Privacy Rights

9.1 California residents (CCPA/CPRA)

The California Consumer Privacy Act, as amended by the CPRA, gives California residents rights over personal information collected by covered businesses, including the right to know/access, delete, correct, and limit use of sensitive personal information, and the right to non-discrimination for exercising these rights. Because we do not sell or share personal information for cross-context behavioral advertising, opt-out and Global Privacy Control mechanisms are not currently applicable to our data practices. [[Confirm current CCPA "business" threshold applicability (revenue / volume of CA consumers) with counsel; the rights below are offered as a matter of policy regardless of strict statutory applicability.]]

• Right to know/access the categories and specific pieces of personal information we hold about you.
• Right to delete personal information we have collected from you, subject to certain exceptions.
• Right to correct inaccurate personal information.
• Right to limit use of sensitive personal information (we currently limit our own use of such data to providing the Service).
• Right to non-discrimination for exercising any of these rights.

9.2 Turkey (KVKK Article 11)

Under KVKK Article 11, you have the right to:

• Learn whether your personal data is being processed and request information about it;
• Learn the purpose of processing and whether your data is used consistently with that purpose;
• Know the third parties to whom your data is transferred, domestically or abroad;
• Request correction of incomplete or inaccurate data;
• Request deletion or destruction of your data where the grounds for processing no longer apply;
• Object to a result that is against you, arising from analysis of your data exclusively through automated systems;
• Claim compensation for damages arising from unlawful processing.

9.3 All users

Regardless of location, you can access and edit most profile information in-app, delete individual decisions or reports, or delete your account entirely from Settings. To exercise any right described in this Section, contact us at [[support email]]. We will respond within the timeframe required by applicable law (generally 30-45 days).

10. Children's Privacy

Numira is not directed to, and is not intended for use by, anyone under 18. We do not knowingly collect personal information from children. If we learn that we have collected personal information from someone under 18, we will delete it. Contact us at [[support email]] if you believe a child has provided us information.

11. Security

We use administrative, technical, and physical safeguards designed to protect your information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Accessing This Policy

This Policy is available on our website and, per applicable requirements for mobile applications, is also directly accessible within the App via Settings → Legal → Privacy Policy.

13. Changes to This Policy

We may update this Policy from time to time. Material changes will be notified in-app or by email before they take effect. The "Last updated" date above reflects the most recent revision.

14. Contact Us

Croncode LLC
[email protected]
+1 (941) 599-0683
Head OffIce USA
CRONCODE LLC
1209 Mountain Road Pl NE, Ste N
Albuquerque,
NM 87110, USA
Turkey OffIce
Incubation İstanbul
No:38, 34295
Kucukcekmece/İstanbul

This document is a compliance-oriented draft prepared to reflect current CCPA/CPRA (Cal.), KVKK (Turkey), and Apple App Store requirements as of mid-2026. It is not a substitute for review by qualified U.S. and Turkish counsel before publication.