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EU/UK Privacy Rights (GDPR)

GDPR / UK GDPR Notice

Effective date: July 25, 2026 · Last updated: July 25, 2026

This notice supplements our Privacy Policy and describes privacy rights available to residents of the European Economic Area, the United Kingdom, and Switzerland under the General Data Protection Regulation and UK GDPR (collectively, "GDPR"). BaZiWar is operated by Ofye Group · Luxey Holdings. App store listings and product development are handled by Luxey Holdings.

1. Data Controller

For the purposes of GDPR, Luxey Holdings and Ofye Group act as joint data controllers for personal data processed through the BaZiWar Service. Contact details are in Section 8 below.

2. Legal Basis for Processing

  • Contract — processing your account, birth data, and chart information to provide the Service you signed up for.
  • Consent — optional features you opt into (e.g. marketing email, certain notifications). You can withdraw consent at any time.
  • Legitimate interests — securing the Service, preventing abuse, and improving features, balanced against your rights.
  • Legal obligation — where we must retain or disclose data to comply with applicable law.

3. Your Rights Under GDPR

Subject to certain exceptions, you have the right to:

  • Access — request a copy of the personal data we hold about you.
  • Rectification — request correction of inaccurate or incomplete data.
  • Erasure — request deletion of your personal data ("right to be forgotten"), subject to legal exceptions.
  • Restrict processing — request that we limit how we use your data in certain circumstances.
  • Data portability — request your data in a structured, machine-readable format, or have it transferred directly to another provider where technically feasible.
  • Object — object to processing based on legitimate interests, including profiling.
  • Withdraw consent — where processing is based on consent, withdraw it at any time without affecting prior lawful processing.
  • Lodge a complaint — with your local data protection supervisory authority, if you believe our processing violates GDPR.

4. International Data Transfers

BaZiWar's infrastructure providers (including Supabase, OpenAI, Stripe, Cloudflare, and Resend) may process data outside the EEA/UK, including in the United States. Where this occurs, we rely on appropriate safeguards such as Standard Contractual Clauses or the providers' own certified transfer mechanisms.

5. Automated Decision-Making

BaZi chart calculations and Xia BaZiWar Coach outputs are generated algorithmically and by AI, but are provided as informational/coaching content — they do not produce legal or similarly significant effects about you, and no fully automated decision is made about your access to the Service based on this output.

6. Retention

We retain personal data only as long as needed to provide the Service and meet legal obligations. See our Privacy Policy for retention details.

7. How to Submit a Request

To exercise your rights, contact us at:

  • Email: support@baziwar.com with subject line "GDPR Rights Request"
  • Or: info@ofyegroup.com (Ofye Group) or info@luxeyholdings.com (Luxey Holdings)

Include your full name, the email address associated with your BaZiWar account, and the specific right(s) you wish to exercise. We may need to verify your identity before processing your request. We will respond within one month of receiving a verifiable request, extendable by two further months for complex requests, in which case we will notify you.

8. Contact — Privacy Inquiries

Ofye Group (Operator · Finances & Billing)
info@ofyegroup.com

Luxey Holdings (Operator · App Store Listing · Product Development)
info@luxeyholdings.com

Privacy requests: support@baziwar.com

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