Privacy policy

Last updated: 22 October 2026 · DRAFT — have this reviewed by counsel before publishing.

Who we are

The controller is Turtle Luck LC SA, avenue d'Ouchy 30, 1006 Lausanne, Switzerland (CHE register CH17030250205). Contact: turtleluckco@gmail.com. We process personal data under the Swiss Federal Act on Data Protection (revFADP) and, where applicable, the EU GDPR.

What we collect

• Account: email address, optional name, sign-in timestamps (passwordless magic-link login).
• Consent records: the date and time you accepted the Terms, and — only if you ticked the separate, optional box — the date and time you opted in to marketing emails.
• Analyses: birth dates/times and results you choose to save to your account.
• Technical: IP address, processed transiently for security (bot protection via Cloudflare Turnstile and rate limiting).

Why (legal bases)

• Providing the service and your account — contract.
• Security and abuse prevention — legitimate interest.
• Newsletter/marketing emails — your consent only (opt-in; the box is never pre-ticked). Withdraw anytime in your account or via the unsubscribe link.

Processors

Cloudflare, Inc. (hosting, Turnstile, CDN) and Supabase, Inc. (authentication and database). Data may be processed outside Switzerland/EEA under Standard Contractual Clauses or equivalent safeguards.

Retention

Account data and saved analyses are kept until you delete them or your account. Consent records are kept as long as needed to prove consent, and deleted with your account.

Your rights

You may access, correct, export and delete your data, withdraw consent, and object to processing. You can delete your account and all saved analyses yourself on the Account page, or email us. You may lodge a complaint with the Swiss FDPIC or your local supervisory authority.

Cookies

We use only strictly necessary storage (your login session in your browser's local storage) and Cloudflare Turnstile. No advertising trackers.