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Privacy Policy

Last updated: April 6, 2026

Data Controller

CrushIT, operated by Roman Nikitin, based in Spain ("we", "us", "our"), is the data controller for the Skein mobile application ("the App"). Skein was previously known as "Tarot Deck" during development.

Contact: r.nikitin.crushitapp@gmail.com

Information We Collect

Information You Provide

Information Collected Automatically

Information We Do NOT Collect

Legal Basis for Processing (GDPR Art. 6)

Processing Activity Legal Basis
Account creation & authentication Consent (Art. 6(1)(a))
App functionality (readings, journal, sync) Contract performance (Art. 6(1)(b))
Push notifications Consent (Art. 6(1)(a)) — opt-in required
Usage analytics Legitimate interest (Art. 6(1)(f)) — improving the App
Purchase verification Contract performance (Art. 6(1)(b))
Security & fraud prevention Legitimate interest (Art. 6(1)(f))

How We Use Your Information

Data Storage & Transfers

Data Processors

We use the following third-party processors, all with Data Processing Agreements (DPAs) or equivalent safeguards:

Processor Purpose Data Location Safeguards
Supabase Database, auth, storage EU (Frankfurt) GDPR-compliant, DPA
PostHog Analytics EU (Frankfurt) GDPR-compliant, DPA
RevenueCat Purchase verification US Standard Contractual Clauses
Apple Authentication, IAP US/EU GDPR commitments
Google Authentication US/EU Standard Contractual Clauses

Data Sharing

We do not sell, rent, or share your personal information with third parties for marketing purposes. Data is shared only with the processors listed above for the purposes described, and when required by law.

Your Rights

You can:

GDPR Rights (Art. 15-22)

As our operations are based in Spain, we comply with the General Data Protection Regulation (GDPR). You have the right to:

To exercise these rights, contact us at r.nikitin.crushitapp@gmail.com. We will respond without undue delay, and in any event within 30 days (extendable by 60 days for complex requests, with notification).

You may also lodge a complaint with the Spanish Data Protection Authority (AEPD): www.aepd.es.

Children's Privacy

The App is not directed at children under 16 in the EU or under 13 elsewhere. We do not knowingly collect information from children. If we become aware that a child has provided personal data, we will delete it promptly.

Data Retention

Data Type Retention Period
Account data Until you delete your account
Journal entries & readings Until you delete them or your account
Analytics (anonymized) Up to 12 months
Push tokens Removed on sign out or uninstall
Purchase records Retained for legal/tax obligations (up to 7 years)

After account deletion, all personal data is removed from our servers within 30 days, except where retention is required by law.

Security

We implement appropriate technical and organizational measures (GDPR Art. 32):

Changes to This Policy

We will notify you of material changes to this policy through:

For significant changes affecting your rights or how we process your data, we will provide at least 14 days' notice before the changes take effect. Continued use after the notice period constitutes acceptance.

Contact

If you have questions about this Privacy Policy or wish to exercise your GDPR rights:

Email: r.nikitin.crushitapp@gmail.com

Data Protection Authority: AEPD — www.aepd.es