Privacy Policy for Cup of Fortune
This Privacy Policy describes how Imarum GmbH (“we,” “us,” or “our”) collects, uses, and shares information about you when you use our mobile application, Cup of Fortune (the “App”).
§1. Data Controller The party responsible for the processing of your personal data (the data controller) is:
Imarum GmbH Schloßschmidstraße 5, 80639 Munich Germany
For any questions or requests regarding your data and privacy, please contact us at: support@cupoffortune.com
§2. What Data We Collect and Why We collect data to provide and improve our service. The collection is based on different legal grounds under the General Data Protection Regulation (GDPR).
A. Information You Provide Directly Account Information: When you create an account, we collect your first name, email address, and a password.
Purpose: To create and manage your account, secure your access, and communicate with you about your account.
Legal Basis: Performance of a contract (Art. 6(1)(b) GDPR).
User Content: To use the App’s core feature, you provide a question (text) and an image of a tea cup.
Purpose: To process your request and generate your AI-based fortune reading. We store this content in your account so you can view your past readings. We do not use your questions or images to train our AI models.
Legal Basis: Performance of a contract (Art. 6(1)(b) GDPR).
B. Information We Collect Automatically Usage and Device Data: When you use the App, we automatically collect certain information through our service providers (Google Firebase). This may include your IP address, device type, operating system, app version, crash reports, and information about how you interact with the App (e.g., features used, time spent).
Purpose: To ensure the technical functionality of the App, monitor for errors, improve the user experience, and analyze performance.
Legal Basis: Legitimate interest (Art. 6(1)(f) GDPR) to maintain and improve our service.
C. Information Based on Your Consent Push Notifications: We may ask for your permission to send you push notifications through your mobile device.
Purpose: To provide updates, alerts, or other messages related to the App.
Legal Basis: Consent (Art. 6(1)(a) GDPR). You can withdraw your consent at any time by changing the notification settings on your device.
§3. Third-Party Services and Data Sharing We do not sell your personal data. We use trusted third-party service providers to operate our App, who act as data processors on our behalf. These include:
Google Firebase: We use Firebase for core functionalities including user authentication, database (Firestore), file storage (Cloud Storage), crash reporting (Crashlytics), and analytics (Google Analytics for Firebase).
Google Cloud Platform (GCP): The AI model (Vertex AI) that generates your fortune reading is hosted on GCP. Your User Content (question and image) is sent to this service for processing.
§4. International Data Transfers Our service providers, particularly Google, are based in the United States. This means your personal data may be transferred to and stored on servers located outside the European Economic Area (EEA).
We have ensured that such transfers are protected by appropriate legal mechanisms. Specifically, data transfers to Google are governed by Standard Contractual Clauses (SCCs) approved by the European Commission, which provide a legal framework to ensure your data receives a level of protection equivalent to that under GDPR.
§5. Your Rights Under GDPR As a user based in the EU, you have the following rights regarding your personal data:
Right of Access: You can request a copy of the personal data we hold about you.
Right to Rectification: You can request that we correct any inaccurate or incomplete data.
Right to Erasure (“Right to be Forgotten”): You can request that we delete your personal data. We will delete all your data, including your account and past readings, upon request.
Right to Restrict Processing: You can request that we limit the way we use your data.
Right to Object: You have the right to object to our processing of your data based on our legitimate interests.
Right to Data Portability: You can request a copy of your data in a machine-readable format.
Right to Withdraw Consent: You can withdraw your consent for push notifications at any time.
To exercise any of these rights, please contact us at support@cupoffortune.com. We will respond to your request in accordance with applicable law.
You also have the right to lodge a complaint with a supervisory authority, such as the data protection authority in your state (e.g., the Bayerisches Landesamt für Datenschutzaufsicht).
§6. Data Retention We retain your personal data for as long as your account is active. If you request to delete your account, we will permanently delete all associated personal data from our systems in a timely manner.
§7. Children’s Privacy The App is not intended for individuals under the age of 13. We do not knowingly collect personal data from children under 13. If we become aware that we have collected such data, we will take steps to delete it.
§8. Changes to This Privacy Policy We may update this Privacy Policy from time to time. If we make significant changes, we will notify you through the App or by other means, giving you an opportunity to review the changes before they take effect.
Effective Date: October 16, 2025; Last updated: October 16, 2025