Privacy Policy

1. Introduction

Brujula Education Ltd ("we", "us", or "our") operates the website https://fortuna-cookie.app ("Service"). We are committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, and safeguard your information when you visit our website.

2. Data We Collect

We practice data minimization and only collect data necessary to provide our Service:

• Voluntary Information: The name you optionally provide to personalize your fortune, and the theme you select (e.g., love, career).
• Transaction Data: Payment information processed securely by our payment provider (Stripe). We do not store your full credit card details on our servers.
• Technical Data: Information automatically collected when you access our website, such as your IP address, browser type, device information, and standard server logs.

3. How We Use Your Data

We process your data for the following purposes and legal bases under UK GDPR:

• Service Delivery (Performance of Contract): To generate your personalized fortune and process your payment.
• Security & Improvement (Legitimate Interests): To prevent fraud, debug technical issues, and improve the performance of our website.
• Legal Compliance (Legal Obligation): To comply with financial regulations and tax laws regarding transaction records.

4. Third-Party Processors

We use trusted third-party service providers to help us operate our business. These providers act as data processors:

• Stripe: Our payment processor. When you make a purchase, your payment data is processed directly by Stripe.
• Vercel: Hosts our website and provides privacy-friendly analytics (see Section 5).

5. Cookies & Local Storage

We use minimal browser storage to operate the Service:

• localStorage: Used to remember your cookie consent preference and to enforce the one-per-day limit on free fortunes. No personal data is stored.
• sessionStorage: Used to cache your fortune within your current browser session so that refreshing the page does not consume an additional request. This data is automatically cleared when you close the tab.

We do not use tracking cookies or third-party advertising cookies. Our analytics provider (Vercel Analytics) does not set any cookies and does not track users across websites. Stripe may set its own cookies during the checkout process — please refer to Stripe's Privacy Policy for details.

6. Analytics

We use Vercel Analytics to understand how visitors use our website. This service is privacy-friendly and does not use cookies or track users across websites. Visitor counting relies on a hash of your IP address and user-agent string, which produces an anonymous, non-identifiable value.

We collect the following anonymised usage events under our Legitimate Interests legal basis (to improve the Service):

• Page views (automatic)
• Theme selected, checkout started
• Fortune shared (method used, e.g. native share or download)
• Gift fortune opened, referral code copied

These events include only the theme name and sharing method — no names, fortune text, session IDs, or personally identifiable information is sent. For more details, see Vercel's Analytics Privacy Policy.

7. Image Sharing

After receiving your fortune, you may generate a shareable image card. This image is created entirely on your device (client-side) and is not uploaded to our servers. If you choose to share it via social media or messaging apps, that sharing is governed by the respective platform's privacy policy.

8. Data Retention

We retain personal data only for as long as necessary:

• Payment Records: Retained for the period required by UK tax and accounting laws (typically 6 years).
• Session Data: Temporary data used to generate your fortune is typically not stored permanently after the session ends, unless required for debugging or security logs which are rotated regularly.

9. Your Rights (UK GDPR)

Under the UK GDPR, you have the following rights regarding your personal data:

• The right to access the personal data we hold about you.
• The right to request rectification of inaccurate data.
• The right to request erasure ("right to be forgotten").
• The right to restrict processing of your data.
• The right to object to processing.
• The right to data portability.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) in the UK if you believe your data rights have been violated.

10. Contact Us

To exercise your rights or if you have questions about this Privacy Policy, please contact us at:
info@fortuna-cookie.app