Legal

Privacy Policy

NUMA LABS LTD · Company No: 17134054 · ICO Registration: C1912276 · Version 1.0 · Effective 21 May 2026

NUMA LABS LTD ("we", "us", "our") is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use the Numa application ("App"), and sets out your rights under UK GDPR and the Data Protection Act 2018.

We are the Data Controller for the purposes of UK GDPR. We are registered with the Information Commissioner's Office (ICO) under registration number C1912276.

Please read this policy carefully. By using the App, you confirm that you have read and understood how we process your personal data.

1. Data We Collect

We collect only the minimum personal data necessary to provide the App's services (data minimisation principle). The categories of personal data we collect are:

1.1 Data You Provide to Us

• Full name — used to calculate your Expression, Soul Urge, and Personality numerology numbers.
• Date of birth — used to calculate your Life Path, Personal Year, Personal Month, Personal Day, and related numerological readings.
• Email address — used for account authentication and service communications.

1.2 Data Collected Automatically

• Device information — device type, operating system version, and App version, used for technical support and compatibility.
• Usage data — features accessed and App interaction patterns, used to improve the service (collected in anonymised or aggregated form where possible).
• Crash reports — diagnostic data generated when the App encounters an error.

1.3 Data We Do Not Collect

We do not collect: financial or payment information (processed solely by Apple); precise geolocation data; biometric data; racial or ethnic origin; religious beliefs; health data; sexual orientation; or political opinions.

2. Legal Basis for Processing

We process your personal data on the following legal bases under UK GDPR:

• Contract performance (Article 6(1)(b)): Processing your name and date of birth is necessary to generate your numerological readings and provide the service you have contracted for.
• Legitimate interests (Article 6(1)(f)): Processing usage and technical data to improve the App and maintain its security, where your interests and rights do not override ours.
• Legal obligation (Article 6(1)(c)): Retaining certain records where required by applicable law.
• Consent (Article 6(1)(a)): Where we rely on consent, including for optional push notifications, you may withdraw consent at any time without affecting the lawfulness of prior processing.

3. How We Use Your Data

We use your personal data to:

• Generate and deliver personalised numerological readings within the App.
• Authenticate and manage your account.
• Provide customer support.
• Send service-related communications (e.g. account confirmation, significant policy changes).
• Maintain the security and integrity of the App.
• Comply with our legal obligations.
• Improve and develop the App's features, where data is anonymised or aggregated.

We do not use your personal data for automated decision-making that produces significant legal or similarly significant effects on you.

4. AI Processing

Your data, including your name and date of birth, is used as input to our AI system to generate your personalised readings. The AI processes this data solely to produce your reading within the session. We do not use your personal data to train or fine-tune AI models without your explicit consent.

Our AI system operates under strict security boundaries: it can only access the data of the currently authenticated user, and is prohibited from accessing, referencing, or combining data from other users.

5. Push Notifications

If you opt in to push notifications, we will send you notifications relevant to your numerological readings and App updates. Opt-in is explicit and separate from the iOS system permission request.

You can withdraw consent for push notifications at any time by adjusting your settings within the App or through your device's notification settings. Withdrawal does not affect the lawfulness of notifications sent prior to withdrawal.

6. Data Sharing and Third Parties

We do not sell your personal data. We do not share your personal data with third parties for their own marketing purposes.

We may share your data with the following categories of third parties, only to the extent necessary to provide the App:

• Cloud infrastructure providers — to host the App and store data securely.
• AI service providers — to process your data and generate readings.
• Analytics providers — using anonymised or aggregated data only, to understand App usage.
• Apple Inc. — as required by the App Store platform for distribution and in-app purchase processing.

All third-party processors are contractually bound to process your data only on our instructions and in compliance with UK GDPR. Where data is transferred outside the UK or EEA, we ensure appropriate safeguards are in place (such as Standard Contractual Clauses or adequacy decisions).

We may also disclose your data: (a) if required to do so by law or legal process; (b) to protect the rights, property, or safety of Numa, our users, or others; or (c) in connection with a business transfer, merger, or acquisition, in which case we will notify you.

7. Data Retention

We retain your personal data for as long as your account is active. When you delete your account, we will permanently delete your personal data from our systems within 30 days, subject to any data we are legally required to retain (such as financial records required by HMRC, which we retain for 6 years).

Anonymised and aggregated data that cannot be used to identify you may be retained indefinitely for analytical purposes.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include encryption of data in transit and at rest, access controls, and regular security reviews.

No method of transmission over the internet or electronic storage is completely secure. While we take reasonable steps to protect your data, we cannot guarantee absolute security.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the ICO as required by UK GDPR.

9. Your Rights Under UK GDPR

You have the following rights in relation to your personal data:

• Right of access — to request a copy of the personal data we hold about you.
• Right to rectification — to request correction of inaccurate or incomplete personal data.
• Right to erasure — to request deletion of your personal data where there is no legitimate reason for us to continue processing it.
• Right to restriction of processing — to request that we restrict processing of your data in certain circumstances.
• Right to data portability — to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to object — to object to processing based on legitimate interests.
• Rights related to automated decision-making — to not be subject to solely automated decisions that produce significant effects.
• Right to withdraw consent — where processing is based on consent, to withdraw that consent at any time.

To exercise any of these rights, contact us at hello@numa-app.co. We will respond within one month of receiving your request. We may need to verify your identity before processing your request.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

10. Account Deletion and Data Erasure

You can delete your account at any time from within the App. Account deletion triggers permanent deletion of all personal data we hold about you from our live systems within 30 days, subject to legal retention obligations.

Account deletion cannot be reversed. All readings, settings, and account history will be permanently lost.

11. Children's Privacy

Numa is not intended for users under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under 16 without appropriate consent, we will take steps to delete that information.

If you believe we have inadvertently collected data from a child under 16, please contact us immediately at hello@numa-app.co.

12. Cookies and Tracking Technologies

As a native iOS application, Numa does not use browser cookies. We may use equivalent mobile tracking technologies (such as device identifiers) for analytical and security purposes. Where we do so, we will obtain your consent where required by law.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of material changes via the App or by email. The date of the most recent revision is indicated at the top of this policy.

Continued use of the App after a revised policy has been posted constitutes acceptance of the revised policy. If you do not agree with the revised policy, you must stop using the App and delete your account.

14. Contact and Data Controller Information

If you have any questions, concerns, or requests relating to this Privacy Policy or our data practices, please contact:

Data Controller: NUMA LABS LTD
Company No: 17134054
Registered Office: 3202 Sky View Tower, 12 High St, London E15 2GU
Email: hello@numa-app.co
ICO Registration: C1912276

We aim to respond to all data-related enquiries within 30 days.