Privacy Policy
Last Updated: February 22, 2026
1. Introduction
This Privacy Policy explains how G Wright Enterprises LLC ("we," "us," or "our"), operating as Cosmic Array, collects, uses, and protects your personal data when you use our website at cosmicarray.io ("the Service").
We are committed to protecting your privacy. Because our server is located in Germany, the EU General Data Protection Regulation (GDPR) and the German Telecommunications-Telemedia Data Protection Act (TTDSG) apply as our baseline compliance framework.
2. Data Controller
G Wright Enterprises LLC DBA Cosmic Array 13027 Victory Blvd, Suite 412 Los Angeles, CA 91606, United States of America Server Location: Germany
Email: [email protected] You may also contact us via our Support page.
3. Data We Collect
A. Birth Data (Provided by You)
- Full name, date of birth, time of birth, and location of birth
- Pronouns (optional, used only for report phrasing)
- Eye color and blood type (optional)
B. Biometric Data (Provided by You)
- Palm photographs for palmistry analysis (Alchemist tier and above)
C. Payment Data (Collected by Stripe)
- Payment method details, email address, and billing information are collected directly by Stripe. We never receive or store your full credit card number.
D. Device and Browser Information
- IP address, browser type, device type, operating system, and referring URL may be collected for site security and performance monitoring.
4. How We Use Your Data
| Purpose | Data Used | Legal Basis (GDPR Art. 6) |
|---|---|---|
| Blueprint generation | Birth data, palm photos, name | Consent (Art. 6(1)(a)) |
| Payment processing | Payment details via Stripe | Contract performance (Art. 6(1)(b)) |
| Site security & abuse prevention | IP address, device info | Legitimate interest (Art. 6(1)(f)) |
| Analytics & improvement | Aggregated usage data | Consent (Art. 6(1)(a)) |
5. Biometric Data (Palmistry)
Your palm photographs are processed in temporary server memory for real-time AI analysis. We do not store palm images. They are permanently deleted from memory immediately after your analysis is generated. No biometric templates or fingerprints are derived or retained.
6. Data Retention
- Birth data and palm images: Not stored. Processed in real-time and discarded immediately after blueprint generation.
- Payment records: Retained by Stripe in accordance with Stripe's Privacy Policy. We retain only a confirmation token that payment was successful.
- Cookie consent preferences: Stored locally in your browser (localStorage) for up to 1 year.
- Cosmic keys (access tokens): Stored locally in your browser for session restoration.
7. Third-Party Processors & International Data Transfers
To provide the Service, we share specific data with the following third-party processors:
| Processor | Purpose | Location | Transfer Mechanism |
|---|---|---|---|
| Stripe | Payment processing | United States | EU-US Data Privacy Framework |
| OpenAI | AI report generation | United States | EU-US Data Privacy Framework |
| Google (Gemini) | AI report generation | United States | EU-US Data Privacy Framework |
| Cloudflare | CDN, DDoS protection, bot management | Global | Standard Contractual Clauses |
These processors are contractually bound to process your data only as instructed by us and in compliance with applicable data protection laws. EU-to-US data transfers rely on the EU-US Data Privacy Framework and, where applicable, Standard Contractual Clauses (SCCs).
We do not sell your data to advertisers or any third parties.
8. Cookies
We use essential cookies to operate the Service and, with your consent, analytics cookies to improve it. For full details, see our Cookies Policy.
9. Your Rights Under GDPR
If you are located in the European Economic Area (EEA), you have the following rights:
- Right of Access (Art. 15): Request a copy of the personal data we hold about you.
- Right to Rectification (Art. 16): Request correction of inaccurate personal data.
- Right to Erasure (Art. 17): Request deletion of your personal data ("right to be forgotten").
- Right to Restriction (Art. 18): Request that we restrict the processing of your data.
- Right to Data Portability (Art. 20): Receive your data in a structured, machine-readable format.
- Right to Object (Art. 21): Object to processing based on legitimate interests.
- Right to Withdraw Consent (Art. 7(3)): Withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
- Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority. For Germany, this is the Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI) or your relevant state data protection authority. You may also contact any EU Data Protection Authority in your country of residence.
To exercise any of these rights, contact us via our Support page.
Since we do not store personal data after blueprint generation, most requests will be addressed by confirming that no personal data is retained.
10. Your Rights Under CCPA (California Residents)
If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA):
- Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected.
- Right to Delete: You may request deletion of your personal information.
- Right to Opt-Out of Sale: We do not sell your personal information. No opt-out is necessary.
- Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
11. Children's Privacy
Cosmic Array is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us immediately.
12. Security
We implement appropriate technical and organizational measures to protect your data, including encrypted connections (HTTPS/TLS), Cloudflare DDoS protection, and secure server infrastructure located in Germany.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated by updating the "Last Updated" date at the top of this page. Continued use of the Service after changes constitutes acceptance of the updated policy.
14. Contact Us
For any privacy-related questions or to exercise your data rights, please reach out through our Support page.