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Mida Privacy Policy

1. Data Controller Information

2. What Data We Collect

Mida collects and processes data under a tiered model. The scope, destination, and toggle state of each tier:

Data categoryContentsCan it be turned off
Account informationLogin credentials (email / phone number / WeChat / Apple account binding); date of birth (day granularity only, used for age verification)Required for the account
Sensitive birth dataBirth time and place (used for chart calculation to build your profile); stored with field-level encryption, every read leaves an audit trailWithdrawable anytime; withdrawal deletes time and place
Derived productsReports, daily cards, synastry records and other derived content; products store only derived hashes, no originals to restoreDeleted with the account
Crash & performance diagnosticsCrash reports and device performance data (device-level anonymous identifier; no birth data or personal data)Cannot be turned off separately (see Section 8)
Anonymous aggregate statisticsTruly anonymized statistics such as page views and feature usage (no user identifier, no device identifier)Cannot be turned off (not individually identifiable)
Usage analyticsUser-level behavioral events (event names and context properties; the user identifier is a server-generated UUID — no email / phone number / birth data)Turn off anytime (see Section 6)

Minors: the service is provided only to users aged 18 or above; age is verified from the date of birth at registration. We do not knowingly collect personal data from anyone under 18.

3. Purposes and Legal Bases

Processing activityPurposeLegal basis (GDPR Art. 6)
Account & age verificationProviding the service; enforcing the 18+ thresholdContract performance (6(1)(b)) / legitimate interests
Sensitive birth data processingChart calculation and profile generationExplicit consent (Art. 9(2)(a), withdrawable anytime)
Crash & performance diagnosticsKeeping the service stable (necessary for service operation)Legitimate interests (6(1)(f), see Section 8)
Anonymous aggregate statisticsAnalyzing feature usageLegitimate interests (truly anonymized data is no longer personal data)
Usage analyticsUser-level behavioral analysis (see Section 4 for the cross-border note)Consent (6(1)(a)) — default off at first launch in the EEA/UK; starts only if you turn it on
Payment recordsOrder handling and statutory accountingContract performance / legal obligation

4. Third-Party Processors

We engage third-party processors only within the following scope:

PostHog (product analytics, only while usage analytics is on)

GlitchTip (crash & error monitoring, always on)

Other processors (each touches only the minimum data its function requires):

4b. Cross-Border Transfer Mechanism

Usage analytics (PostHog Cloud US) constitutes a transfer of personal data outside the EEA/UK. The safeguard we rely on is the Standard Contractual Clauses (SCCs), incorporated in the Data Processing Agreement (DPA) executed with PostHog, Inc. (see posthog.com/dpa). The self-hosted GlitchTip instance is deployed in the same region as the service and does not constitute a cross-border transfer (see Section 4).

5. Session Replay and Masking

6. How to Opt Out

7. EU Default Off (EEA/UK opt-in)

For users located in the European Economic Area (EEA) or the United Kingdom, usage analytics is off by default at first launch — this is the GDPR opt-in requirement for user-level behavioral analytics going to an overseas third party: nothing is collected by default; collection starts only if you actively turn it on. Outside the EEA/UK the default may be on, and you can still turn it off anytime. The default is decided by your region when the app fetches configuration; after cross-region travel, returning to the foreground triggers a fresh fetch.

8. Crash Diagnostics Processing Activity

9. Data Retention

DataRetention
Account & derived productsDeleted with account deletion (irreversible deletion within 15 working days)
Data export filesExpire and are deleted 72 hours after generation
Crash & performance eventsAuto-deleted after 90 days
Usage analytics data (PostHog side)Deletion request issued at account deletion; PostHog clears asynchronously (cleared within 30 days; backup media rotate out under their subsequent backup cycles)
Consent recordsRetained in de-identified form for evidence; deleted after 3 years
Payment & order recordsStatutory accounting period (generally 5 years or more); deleted on expiry
Phone number hashesRetained 30 days after deletion for anti-abuse, then deleted

10. Your Rights (GDPR Art. 15–22)

You have the right to: access your personal data; obtain a portable copy (in-app "Me" → Privacy → export data; the export file is valid for 72 hours); rectify inaccurate data; erase your data (triggered by deleting your account); restrict or object to specific processing; withdraw consent at any time (withdrawal does not affect the lawfulness of processing before it); and lodge a complaint with a supervisory authority. You may exercise these rights via in-app self-service features or the contact details in Section 11.

10b. Data Security Measures

We take appropriate technical and organizational measures to protect personal data under GDPR Art. 32, including: field-level envelope encryption of sensitive fields (birth data, name, date of birth) with keys managed separately from data; audit records on every read of sensitive data; least-privilege database accounts; TLS for all transport; code-level gatekeeping of third-party egress channels (new outbound endpoints must pass a CI gate).

10c. Policy Change Notification

Material changes to this policy (new data categories, new third-party processors, changes to purposes or retention) will be announced in-app before taking effect; changes adding sensitive processing or third-party processors will apply to existing data only after your renewed explicit consent.

11. Contact


The mainland-China distribution track (cn track) is additionally governed by PIPL (Personal Information Protection Law of the PRC) and its implementing rules; see the policy text applicable to that track.