v1.0.0 · 2026-09-08

Privacy Policy

Effective date: 8 September 2026 Last updated: 8 September 2026

This Privacy Policy explains how Xivena collects, uses, shares, and protects your personal data when you use our website at xivena.com and our applications for iPhone and Android (together, the "Service").

Please read it together with our Terms of Use. Creating an account acknowledges that this notice was made available to you; it is not blanket consent to every use of personal data. Where a specific activity legally requires consent — sharing your data with our AI providers is one — we ask for that choice separately, inside the app, and you can withdraw it at any time.

1. Who we are

Xivena is operated by Babakulov Shakhzodbek, an individual sole trader ("Xivena", "we", "us", "our"). For the purposes of UK and EU data protection law, we are the data controller responsible for your personal data.

• Contact for privacy matters: babakulov@xivena.com

We have not appointed a Data Protection Officer, and we have not appointed an EU or UK Representative. You may contact us directly at the address above for any privacy matter.

2. What we collect, why, and on what legal basis

We collect only what we need to run the Service and give you personalised reflections. Under the UK GDPR and EU GDPR (Article 6), our legal basis for each use is one of: performance of our contract with you, your consent, our legitimate interests in operating and improving the Service, or compliance with a legal obligation.

2.1 Identity and account

Your name, email address, and avatar (a photo you upload or an icon you choose), together with the sign-in method you use (Apple, Google, or email), account creation and last sign-in times. If you upload a profile photo, it is stored at a long-lived, unguessable link so the app can display it; anyone who has that exact link could view the photo, and the link changes when you upload a new one. Purpose: create and secure your account. Legal basis: contract.

2.2 Your agreement to our documents

When you create an account, our servers record the version numbers of the Terms of Use, this Privacy Policy, and the Refund Policy that were in force at that moment, the date and time, and which app you signed up from. We also record when we last emailed you about a change to these documents. Purpose: show that the documents were made available to you and know whom to tell when they change. Legal basis: legitimate interest and legal obligation.

2.3 Birth details

Your date of birth and, optionally, your time and place of birth (including the coordinates and time zone derived from the place you enter). Purpose: personalise your readings and, in the apps that offer astrology, calculate your natal chart and transits. Legal basis: contract and, for the optional details, consent.

2.4 Derived signs

Your sun, moon, and rising signs, calculated from your birth details. Purpose: personalise the Service. Legal basis: contract.

2.5 Psychological self-assessment results

Your answers to the in-app questionnaires and the results calculated from them — numeric scores for personality traits (the Big Five, including neuroticism), attachment style, chronotype, values, and strengths. Purpose: build your Portrait; the scores are included in what we send to our AI providers so your reflections and conversations reflect who you are. These are self-reflection tools, not clinical assessments. Legal basis: explicit consent.

2.6 Data about other people

If you use Your People or a compatibility report, you may enter another person's name, birth details, gender, and how you relate to them. Only enter another person's details if you have their permission. What you enter is shared with our AI providers as relationship context when generating reflections for you. Legal basis: consent and legitimate interest.

2.7 Palm photographs (sensitive data)

In the apps that offer palm reading, the photograph you take is stored in Firebase Cloud Storage so we can generate your reading and you can revisit it. We treat palm photographs as sensitive personal data; they may be considered biometric in some jurisdictions. We use them only to generate your palm reading — never to identify you, and never for any other purpose. Legal basis: explicit consent.

2.8 Content you create

Your dream journal entries, the notes you and your companion keep, your saved readings and reflections, your messages to the companion, and your compatibility reports. Purpose: so you can return to them, and as context for future conversations. Legal basis: contract.

2.9 Voice audio

In Expert Voice, your speech streams directly to our voice provider (ElevenLabs) and is transcribed in real time so the AI can respond. In Expert Video, each thing you say is sent to our server, passed to ElevenLabs for transcription, and not kept. Xivena does not store your voice audio on its own servers. ElevenLabs retains session audio recordings and transcripts under its own retention policy and may use them to train and improve its AI models. Withdrawing your AI consent stops any further voice processing. Legal basis: explicit consent.

2.10 Video sessions

When you use Expert Video, the Expert's spoken replies are rendered as an animated avatar by our video provider — the reply audio is sent to LiveAvatar (HeyGen), and the animated avatar is streamed back to you over LiveKit's real-time infrastructure. HeyGen may use that submitted content — the Expert's spoken replies, which can reflect your personal context — to train and improve its models. Your camera is never accessed and no video of you is captured. Your side of the conversation is voice audio, handled as described in section 2.9. Legal basis: consent.

2.11 Companion memory

To make conversations feel continuous, the Service keeps three things derived from your content: short notes the AI writes about you, which you can see and edit in the app; a rolling summary of your recent readings and conversations; and numerical representations ("embeddings") of your entries that let the AI find related moments later. All three are produced by our AI providers from your content and shared back to them as context for future conversations. Legal basis: consent.

2.12 Payment data

Your plan, your purchase history, and the store you bought from. Your card details are handled entirely by the store or payment provider (Paddle on the web, Apple on iPhone, Google Play on Android) and are never seen or stored by Xivena. We receive a confirmation of successful payment, the transaction identifier and, on the website, the amount and currency. Purpose: provide what you bought; meet tax and accounting obligations. Legal basis: contract and legal obligation.

2.13 Usage and game data

Token counters, feature-usage counters, and scores from in-app games. Purpose: operate features, apply plan limits, improve the Service. Legal basis: legitimate interest.

2.14 Technical and security data

Your IP address, request logs, error logs, and rate-limit counters. Purpose: keep the Service secure, reliable, and free from abuse. Legal basis: legitimate interest and legal obligation.

2.15 One free allowance per person — the returning-account marker

Every new account receives a one-time free allowance of tokens. To stop the same person repeatedly deleting and recreating an account to claim it again, when you delete your account we keep one thing: a one-way cryptographic marker derived from your normalised email address using a secret key held only on our servers. The marker does not contain your email address and cannot be turned back into it. It records nothing but the fact that a free allowance was once claimed, the date, and an expiry date.

If a new account is later created with an email address that produces the same marker, that account is opened normally but receives no second free allowance. Paid plans and purchases work as usual. The app tells you when this has happened. If you sign in with Apple and choose to hide your email, the relay address Apple gives us is stable, so the marker still works and we never learn your real address. Purpose: prevent repeated claims of a promotional allowance; keep it fair for genuinely new users; protect the paid AI-processing budget the allowance draws on. Legal basis: legitimate interest. We use the least identifying comparison that works, we do not store the source email in the marker, we do not use device or IP signals for this purpose, and we document the balancing assessment in our internal compliance record. You may object by writing to us (section 8).

2.16 Communications

If you contact us, we keep the email thread and any attachments. Purpose: respond to you and keep a record. Legal basis: legitimate interest.

2.17 Analytics

On the website, Vercel Analytics measures page views and performance (Web Vitals) without cookies and without tracking you across other sites. In the iPhone app, Google Analytics for Firebase records which screens are viewed and which features are used only if you switch it on in Settings; it is off by default. In the Android app it records the same and is on by default; the Android app does not yet have an in-app switch, and you can object by email (section 8). Analytics data is not used to track you across other apps and does not power App Tracking Transparency requests. Legal basis: legitimate interest for the cookie-free website measurement; consent for the mobile analytics.

3. How we use artificial intelligence

Xivena uses AI to generate your Portrait, your companion's replies, dream interpretations, guided reflections and, in the apps that offer them, horoscopes, tarot, palm analysis, and compatibility readings. Depending on the feature, what we send to our AI providers can include: your name; your birth details and derived signs; your questionnaire scores (section 2.5); the people you add (section 2.6); your dream entries, notes, and past readings (section 2.8); your companion memory (section 2.11); your messages; and, for palm reading, the palm photograph. Text is processed by Google Gemini or Anthropic Claude depending on your plan, and each provider is the other's fallback when the first is unavailable. Palm photographs are analysed by Google Gemini, with Anthropic Claude as the fallback.

Before any of your personal data is shared with an AI provider, we ask for your explicit consent inside the app. The AI features only begin once you have agreed, and our servers enforce it: AI features do not run for an account with no recorded consent. You can withdraw that consent at any time in the app at Settings → Privacy → "Withdraw AI consent"; the AI features stop until you agree again, and everything you have saved stays exactly as it is. You can also withdraw by emailing us (section 8).

We do not use AI to make automated decisions that produce legal or similarly significant effects about you. No profiling under Article 22 of the GDPR takes place.

Important: no AI-generated content on Xivena is professional medical, psychological, financial, or legal advice, and no result we give you is a diagnosis. Our self-reflection features are for self-reflection and general information only and are not clinical assessments. Astrology and divinatory content is for entertainment. See sections 5 and 6 of our Terms of Use.

4. Who we share your data with

We share personal data only with the service providers (sub-processors) that help us operate the Service. Each processes data on our behalf under contractual safeguards.

The stores that sell to you are not our sub-processors

Paddle (website), Apple (iPhone app), and Google Play (Android app) sell to you in their own right as Merchant of Record. They decide for themselves how they handle your billing data, so for that data they are independent controllers alongside us, and their own privacy notices govern it: Paddle · Apple · Google. We receive only a confirmation of payment, the transaction identifier and, on the website, the amount and currency.

What our AI providers commit to

From their published terms and policies:

• Google (Gemini) — we use the paid tier of the Gemini API; under its terms, Google does not use your prompts (including images such as your palm photograph) or the generated responses to improve its products.
• Anthropic (Claude) — its commercial terms state it may not train models on API customer content, and API inputs and outputs are deleted from its systems within 30 days under its standard retention policy.
• ElevenLabs — certified under the EU-US Data Privacy Framework and provides a data-processing agreement; it retains session recordings and transcripts under its own retention policy and may use them to train and improve its AI models (section 2.9).
• HeyGen (LiveAvatar) — SOC 2 Type II audited; it may use content submitted to it (the Expert's spoken replies, section 2.10) to train and improve its models, and its agreements with its own AI vendors do not allow those vendors to train on customer data. Only the Expert's synthesized replies reach HeyGen — never your voice and never your camera.
• LiveKit — does not use customer content, prompts, transcripts, or audio to train models, and operates zero retention for AI inference; media is encrypted in transit.

These commitments are not identical. Google, Anthropic, and LiveKit commit not to train on your content; ElevenLabs and HeyGen may. We do not present those two as equivalent to the others. The in-app consent screen states it before you agree, and no session runs until you do. Both are involved only in live voice and video sessions — if you do not use Expert Voice or Expert Video, neither receives anything about you.

We do not sell your personal data. We do not share it with third parties for their own marketing. We may disclose data if required to do so by law, by a court order, or to protect the rights, safety, and security of our users or the Service; where we are permitted to, we will tell you first.

5. International data transfers

Most of our infrastructure and several of our providers are in the United States, so your data may be transferred to and processed outside the United Kingdom and the European Economic Area. Where we make such transfers, we rely on appropriate safeguards such as the UK International Data Transfer Agreement, the EU Standard Contractual Clauses, and the EU-US Data Privacy Framework where applicable. You can ask us for a copy of the safeguards in place by writing to babakulov@xivena.com. Account creation acknowledges this notice; it is not treated as blanket consent to future transfers.

6. How long we keep your data

• Account, profile, and everything you created — kept while your account is active; deleted immediately when you delete your account in the app, and in any event within 30 days.
• Your record of agreement to our documents (section 2.2) — part of your account; deleted with it.
• Palm photographs — deleted when you delete the reading or your account.
• Voice session audio and transcripts — not stored on Xivena's servers; our voice provider retains them under its own policy (section 2.9).
• Payment records — kept for at least 7 years, as required by UK tax and accounting law. They survive account deletion.
• Administrative action records — an append-only log of account-level administrative actions (for example a refund or a plan change made by us), kept after account deletion for accountability. It references your account identifier and the action taken (for a password reset, the address it was sent to) and contains none of your content.
• The returning-account marker (section 2.15) — kept for 24 months after you delete your account, then removed. Creating another account does not extend that period.
• Emails we send you about document changes — the fact that one was sent is part of your account and deleted with it; our email provider keeps delivery logs under its own retention policy.
• Technical and security logs — up to 90 days.
• Support emails — up to 24 months after last contact.

When you delete your account, everything goes except the payment records, the administrative log, and the marker. The deletion screen in the app says the same thing.

7. Your rights

Depending on where you live, you have the right to:

• Access the personal data we hold about you
• Rectification — have inaccurate data corrected
• Erasure — have your data deleted (the "right to be forgotten"); you can do this yourself at any time in Settings → Delete Account
• Restriction — limit how we process your data
• Portability — receive your data in a structured, machine-readable format
• Objection — object to processing based on our legitimate interests, including the returning-account marker
• Withdrawal of consent — at any time, where processing is based on consent; for AI processing, in the app at Settings → Privacy → "Withdraw AI consent", without deleting your account
• Complaint — to a supervisory authority; in the UK, the Information Commissioner's Office (ico.org.uk)

To exercise any of these rights, email babakulov@xivena.com from the address linked to your account. We will respond within 30 days. We do not charge for rights requests except where they are manifestly unfounded or excessive.

8. Contacting us about privacy

For any privacy question, to object to processing, or to withdraw consent by email: babakulov@xivena.com.

9. Children

The Service is intended for adults. You must be at least 18 years old to use Xivena. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with personal data, contact us and we will delete it promptly.

10. Security

We protect your data with technical and organisational measures appropriate to the risks: encryption in transit (TLS), encryption at rest, Firebase security rules that let each account read and write only its own data, server-side checks on every AI request, and access controls that limit who can reach your data — the founder is the only person with production access. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If a breach occurs that poses a high risk to your rights, we will notify you and the relevant authorities as the law requires.

11. Cookies and local storage

We keep our use of cookies and local storage to a minimum:

• Firebase Authentication keeps your sign-in session in your browser's local storage so you stay signed in.
• Paddle.js runs during website checkout to process payment securely.
• Vercel Analytics measures page views and performance without cookies and without tracking you across other sites.
• Local storage on your device holds your session and interface preferences (language, appearance).

In our mobile apps, Google Analytics for Firebase is described in section 2.17.

12. Changes to this Privacy Policy

We may update this Privacy Policy. Each version carries a version number and an effective date at the top of this page. When we make a material change, we will email the address on your account before the change takes effect, telling you what changed and where to read it. We will disclose a new purpose or materially different processing before it begins, and ask for a fresh choice only where that processing legally requires consent. Continued use of the Service after the effective date means you accept the revised policy.

13. Contact

For questions about this Privacy Policy or to exercise your rights: babakulov@xivena.com

Controller: Xivena — Babakulov Shakhzodbek, individual sole trader.