Privacy policy
Last updated: 12 May 2026 | Celestial Connection LLC | 30 N Gould St Ste R, Sheridan, WY 82801
dpo@mg.celestial-connection.com | Summary:
celestial-connection.com/privacy-policy.php
This Full Privacy Policy explains how Celestial Connection LLC and Novarion B.V. (together the “joint controllers” or “we”) collect, use, share, and protect your personal information when you use the Platform at
celestial-connection.com.
1. Joint Data Controllers
Both entities below are joint data controllers under GDPR Article 26. They are operated by the same management team. You may exercise your privacy rights against either entity.
| Entity |
Details |
Role |
| Celestial Connection LLC |
30 N Gould St Ste R, Sheridan, WY 82801, USA
dpo@mg.celestial-connection.com
|
US operating entity. Operates the Platform, runs the quiz funnel, sells own products, collects data at source, obtains user consents. |
| Novarion B.V. |
Morgenweg 49, 5406NJ Uden, Netherlands
dpo@mg.novarion.io
|
Dutch parent company. Group management, financial oversight, IT infrastructure, and strategic purposes. Same management team as Celestial Connection LLC. |
1.3 Joint Controller Arrangement: the two controllers have documented their respective data protection responsibilities in an internal Joint Controller Record. The essence of that arrangement is set out in Section 1.4. A copy is available on request at
dpo@mg.celestial-connection.com.
1.4 Essence of arrangement: Celestial Connection LLC is primarily responsible for obtaining valid user consents, making disclosures to users, handling inbound rights requests, and US privacy law compliance. Novarion B.V. is primarily responsible for EU/EEA regulatory liaison, group-level security standards, and its own internal processing purposes. Because the same team operates both entities, day-to-day decisions are made collectively. Either entity will accept and act on a rights request from you.
1.5 Privacy contact for both entities:
dpo@mg.celestial-connection.com. We acknowledge all requests within 5 business days.
2. Our Business Model — Three Distinct Activities
Activity A — Lead Generation (Free Quiz Funnel)
2.1 The free quiz is a lead generation service. When you submit your contact details and actively consent, Celestial Connection LLC transfers your data to selected third-party Partners. Partners pay us for qualified leads — this funds the free quiz.
2.2 Legal basis: your explicit, prior, affirmative consent (GDPR Art. 6(1)(a); CCPA opt-in for consumers under 16). Without consent, your data is not shared with Partners.
2.3 Celestial Connection LLC and Partners are joint controllers under GDPR Art. 26 for the initial data collection and transfer. Once a Partner receives your data, it is an independent controller for its own subsequent processing.
Activity B — Direct Sales (Own Products)
2.4 Celestial Connection LLC sells its own astrology products, subscriptions, and digital content directly to you. Legal basis: contract performance (GDPR Art. 6(1)(b)).
Activity C — Group Operations (Novarion B.V.)
2.5 Novarion B.V. accesses personal data for group management, financial consolidation, IT governance, risk management, and strategic purposes. Legal basis: legitimate interests of the group (GDPR Art. 6(1)(f)), supported by a documented Legitimate Interest Assessment. You have the right to object — see Section 12.
3. Personal Information We Collect
| Category |
Data Elements |
How Collected |
| Identity |
Full name, date of birth, gender |
Quiz / checkout |
| Contact |
Email address, country of residence |
Quiz / checkout |
| Quiz answers |
Areas of interest, stated concerns, quiz responses |
Quiz |
| Transaction |
Payment method, billing amount, subscription status, purchase history |
Checkout / payment processor |
| Technical |
IP address, browser type/version, device type and OS |
Server logs / cookies |
| Behavioural |
Pages visited, clicks, time on page, quiz funnel progress |
Analytics |
| Retargeting |
Cookie IDs, pixel data, push tokens, ad interaction data |
Retargeting tools |
| Consent records |
Timestamp, disclosure version, affirmative action record, opt-outs |
System-generated |
| Communications |
Emails, support requests, complaints |
You provide directly |
3.2 We do not collect special categories of sensitive personal data (GDPR Art. 9) or sensitive personal information as defined under CPRA. Astrology preferences are entertainment preferences, not health, religious, or other sensitive data.
3.3 Children: We do not knowingly collect personal data from persons under 18. If we discover we have, we delete it promptly. We do not sell or share the data of consumers we know to be under 16.
4. Purposes of Processing and Legal Bases
| Purpose |
Legal Basis |
Detail |
| Partner data sharing (lead gen) |
Consent — explicit, prior, affirmative |
Separate active step at quiz. Freely given, specific, informed, unambiguous. Withdrawable at any time without penalty. |
| Subscription / purchase fulfillment |
Contract performance |
Necessary to perform your contract with Celestial Connection LLC. |
| Payment processing |
Contract performance + legal obligation |
Necessary to collect payment; required by payment card rules. |
| Transactional emails |
Contract performance |
Order confirmations, billing notices, renewal reminders. |
| Account management |
Contract performance |
Administering your customer relationship. |
| Fraud prevention / security |
Legitimate interest |
Protecting the Platform and users. Minimised and proportionate. |
| Retargeting advertising |
Consent (cookie) |
Only with prior cookie consent. Withdrawable via banner. |
| Interest profiling |
Legitimate interest |
Personalising content. No legally significant automated decisions. You may object. |
| Group management — Novarion B.V. |
Legitimate interest |
Group financial reporting, IT oversight, strategic management. You may object (Section 12). |
| Statutory accounting records |
Legal obligation |
US federal/state tax and accounting law — 7 years. |
| Consent records |
Legal obligation / legitimate interest |
Demonstrating compliance. Retained 3 years. |
| Anonymised analytics |
Not applicable (not personal data) |
PII stripped. Retained indefinitely. |
4.2 There is no legitimate interest basis for quiz funnel Partner sharing. That processing requires and only occurs with your explicit consent.
5. Cookies and Tracking Technologies
5.1 We obtain your prior consent before placing non-essential tracking technologies, consistent with applicable US state laws (CCPA/CPRA) and, for EU/EEA users, the ePrivacy Directive.
| Type |
Purpose |
Consent Required? |
| Strictly necessary |
Platform functionality, session, security |
No — legally exempt |
| Analytics |
Platform usage in aggregate |
Yes |
| Retargeting / advertising |
Personalised ads based on prior visits |
Yes |
| Functional |
Preferences, language, quiz progress |
Yes |
5.2 Retargeting providers: NotifyAI (push notifications/retargeting; cookie IDs and device identifiers); Pushnami LLC (US — push tokens, device identifiers; EU/EEA transfers: SCCs, Decision 2021/914).
5.3 Manage preferences via the cookie banner or at
celestial-connection.com/cookie-policy.php.
6. Partner Data Sharing — Lead Generation
This section explains in full what data is shared with Partners, on what legal basis, and your rights.
6.1 Data transferred to Partners with your consent: full name; date of birth; email address; gender; country of residence; quiz answers and stated interests.
6.2 Partners offer astrology, tarot, clairvoyance, and spiritual services. They contact you with personalised commercial offers. They do not receive your payment data or purchase history.
6.3 A current Partner list is available within one month of request:
dpo@mg.celestial-connection.com.
6.4 Legal basis: explicit, prior, affirmative consent — obtained by a separate, active step at quiz submission. Completing the quiz, submitting your email, or accepting Terms is not consent.
6.5 For EU/EEA users: Celestial Connection LLC and Partners are joint controllers (GDPR Art. 26) for the initial transfer. Once a Partner receives your data, it is an independent controller for subsequent processing.
6.6 Partner obligations: all Partners are contractually required to use your data only for disclosed purposes; comply with all applicable law including CAN-SPAM and state privacy laws; honour opt-out requests promptly; and indemnify Celestial Connection LLC for claims from their own unlawful conduct.
Consent Withdrawal and Opt-Out
6.7 Withdraw at any time, at no cost, with no penalty: (a) unsubscribe link in any Partner email; (b)
celestial-connection.com/data-processing-consent-withdrawal.php; (c)
dpo@mg.celestial-connection.com.
6.8 Upon withdrawal: transfers stop within 24–72 hours; Partners notified and must cease processing. Not retroactive for data Partners already received.
California Residents — CCPA/CPRA
6.9 Transfer of data to Partners for commercial consideration = “sale” and/or “sharing” under CCPA/CPRA. Opt out at:
celestial-connection.com/data-processing-consent-withdrawal.php. Processed within 15 business days.
6.10 We do not sell or share the personal information of consumers we know to be under 16.
7. All Recipients of Your Personal Information
| Recipient |
Purpose |
Location |
Transfer Basis |
| Novarion B.V. (joint controller) |
Group management, IT, reporting |
Netherlands (EU) |
Intra-group record + SCCs |
| Lead generation Partners |
Commercial contact (Section 6) |
US, EU/EEA, other |
Consent; SCCs outside EEA |
| Payment processors (e.g. Stripe) |
Secure payment processing |
US and EU/EEA |
EU-US DPF; SCCs |
| Transactional email platform |
Order confirmations, billing reminders |
US or EU/EEA |
SCCs / DPA |
| Analytics providers |
Platform analytics |
US |
SCCs; IP anonymisation |
| Retargeting (NotifyAI, Pushnami) |
Retargeting advertising |
US and EU/EEA |
SCCs |
| Cloud hosting providers |
Platform infrastructure |
US preferred |
DPA; SCCs |
| Legal / regulatory authorities |
Court orders, legal obligations |
As required |
Legal obligation |
| Potential acquirers |
M&A / restructuring |
TBD |
SCCs or adequacy; users notified |
8. International Data Transfers
8.1 Celestial Connection LLC is based in Wyoming, USA. Novarion B.V. is based in the Netherlands, EU. Because the same team operates both entities, data flows continuously in both directions and is treated as jointly held.
8.2 EU→US transfers: governed by Standard Contractual Clauses (EU Commission Decision 2021/914, Module 1 — controller-to-controller).
8.3 US→EU transfers: governed by the same SCCs in reverse direction and/or GDPR Art. 6(1)(f) legitimate interest.
8.4 For UK users: transfers are subject to the UK International Data Transfer Agreement (IDTA).
8.5 Request a copy of applicable transfer safeguards:
dpo@mg.celestial-connection.com.
9. Data Retention
| Data Category |
Retention Period |
What Happens After |
| Quiz/contact — active paid subscriber |
Subscription + 24 months after last activity |
Anonymised |
| Quiz/contact — free user, engaged |
24 months from last engagement |
Anonymised |
| Quiz/contact — free user, never engaged |
12 months from collection |
Anonymised |
| Lead transfer records (our systems) |
12 months (24 if documented engagement) |
Deleted. Partners manage own retention. |
| Consent records |
3 years from consent or last contact |
Deleted |
| Payment / transaction records |
7 years (US federal/state accounting law) |
Deleted |
| Cookie consent records |
1 year from consent |
Renewed or deleted |
| Server logs (IP addresses) |
90 days |
Deleted |
| Novarion B.V. group records |
Per Novarion B.V. retention schedule (available on request) |
Deleted or anonymised |
| Anonymised analytics |
Indefinitely (not personal data) |
N/A |
10. Security
10.1 Technical and organisational measures: TLS encryption in transit; role-based access controls; regular security reviews; contractual security obligations on all processors and Partners; group-level security standards set by Novarion B.V. and implemented by Celestial Connection LLC.
10.2 Breach notification: (a) US state residents — notified per applicable state breach notification laws; (b) EU/EEA users — Autoriteit Persoonsgegevens notified within 72 hours (GDPR Art. 33); individuals notified where required (Art. 34); (c) UK users — ICO notified within 72 hours.
11. Your Privacy Rights — United States
California Residents (CCPA / CPRA)
| Right |
What It Means |
How to Exercise |
| Right to Know |
Categories and specific PI collected, used, disclosed, sold, or shared. |
dpo@mg.celestial-connection.com |
| Right to Delete |
Deletion of your PI, subject to California law exceptions. |
dpo@mg.celestial-connection.com |
| Right to Correct |
Correction of inaccurate PI. |
dpo@mg.celestial-connection.com |
| Right to Opt-Out of Sale/Sharing |
Transfer to Partners = sale/sharing under CCPA/CPRA. |
celestial-connection.com/data-processing-consent-withdrawal.php |
| Right to Non-Discrimination |
No denial of service or different pricing for exercising rights. |
Automatic |
11.2 Response times: Right to Know — 45 days, extendable by 45 with notice; max 2 per 12-month period. Delete/Correct — 45 days. Opt-Out — 15 business days.
11.3 Verification may be required. No account creation required. Authorised agents accepted with proof of authority.
Other US State Residents
11.4 Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Texas (TDPSA), Montana (MCDPA), Oregon (OCPA), and other states with enacted privacy laws have analogous rights to access, correct, delete, and opt out. Response time: 45 days, extendable by 45. Contact:
dpo@mg.celestial-connection.com.
CAN-SPAM Act
11.5 Our commercial emails include our physical address, honest subject lines, and a clear unsubscribe mechanism. We honour opt-out requests within 10 business days. Partners are independently responsible for their own CAN-SPAM compliance.
12. Your Privacy Rights — EU, EEA and UK
You may exercise these rights against either Celestial Connection LLC or Novarion B.V. The same team handles all requests.
| Right |
What It Means |
How to Exercise |
| Access (Art. 15) |
Copy of your data and how it is used. |
dpo@mg.celestial-connection.com |
| Rectification (Art. 16) |
Correct inaccurate or incomplete data. |
dpo@mg.celestial-connection.com |
| Erasure (Art. 17) |
Deletion where no overriding legal basis to retain. |
dpo@mg.celestial-connection.com |
| Restriction (Art. 18) |
Restrict processing while a dispute is resolved. |
dpo@mg.celestial-connection.com |
| Portability (Art. 20) |
Your data in machine-readable format (consent/contract basis). |
dpo@mg.celestial-connection.com |
| Object (Art. 21) |
Object to legitimate interest processing, including Novarion B.V. group management. |
dpo@mg.celestial-connection.com |
| Withdraw Consent (Art. 7(3)) |
Withdraw consent at any time, without penalty. |
celestial-connection.com/data-processing-consent-withdrawal.php |
12.2 Response time: one calendar month. Extension up to two further months for complex requests — with notice within the first month. No fee.
Supervisory Authorities
12.3 Lead authority: Autoriteit Persoonsgegevens (Netherlands) —
www.autoriteitpersoonsgegevens.nl
• Germany: BfDI —
www.bfdi.bund.de
• France: CNIL —
www.cnil.fr
• Italy: Garante —
www.garanteprivacy.it
• Spain: AEPD —
www.aepd.es
• UK: ICO —
www.ico.org.uk
• All EU authorities:
https://edpb.europa.eu/about-edpb/about-edpb/members_en
13. Profiling and Automated Decision-Making
13.1 We use quiz answers and browsing behaviour to create a basic interest profile for selecting relevant Partners (with consent), personalising Platform content, and Novarion B.V. group analytics. No automated decision with legal or similarly significant effect is made about you solely by automated means (GDPR Art. 22). You may object at any time:
dpo@mg.celestial-connection.com.
14. Children
14.1 Platform for users aged 18+. We do not knowingly collect data from minors. If discovered, we delete promptly. We do not sell or share data of consumers known to be under 16.
15. Changes to This Policy
15.1 Material changes: at least 30 days’ advance email notice plus prominent website notice. Previous versions available on request:
dpo@mg.celestial-connection.com.
16. Contact
Joint Controllers: Celestial Connection LLC + Novarion B.V. (same management team)
Privacy contact:
dpo@mg.celestial-connection.com
Consent withdrawal:
celestial-connection.com/data-processing-consent-withdrawal.php
Cookie Policy:
celestial-connection.com/cookie-policy.php
Lead EU authority:
www.autoriteitpersoonsgegevens.nl | UK:
www.ico.org.uk
EU ODR:
https://ec.europa.eu/consumers/odr
© 2026 Celestial Connection LLC / Novarion B.V. | Last updated: 12 May 2026
