Privacy Policy

Effective as of August 26, 2026

By using Niebo Diary Dreams, you are trusting us with your personal information. We want to keep your trust, so it is our company’s policy to do everything possible to protect the personal data and privacy rights of users and to ensure transparency in our data processing practices.

The main purpose of our Privacy Policy is to give you a clear understanding of what data we collect, how it is used and shared, and how you can control these processes.

We recommend that you read this Privacy Policy in full, as well as the Terms of Use, but to start with, here are a few key points that we hope you will find useful.

Data improves your experience with Niebo Diary Dreams

When you use Niebo Diary Dreams, we may collect your Personal Data and use it to improve the user experience, for example by increasing the accuracy of forecasts, personalizing the information you receive, etc. For research, we use only anonymized or aggregated data that cannot be associated with you in any way.

You can contribute to the development of the Niebo Diary Dreams community

If we receive your consent, we will be able to use technical information about you (your unique technical identifier, information about your age group, subscription status, and the fact that you launched the App) for the purposes of promotion and reaching a similar audience. You can withdraw your consent to the transfer of such data at any time.

You are the one in control of your data

You can access your Personal Data and change, correct, delete, and update it by writing to us at realunivers573@gmail.com. By contacting us, you can also download the information collected about you by Niebo Diary Dreams. Remember that deleting or changing some of the Personal Data you have entered may affect your ability to use Niebo Diary Dreams in the future.

Your data is reliably protected by Niebo Diary Dreams

No one: neither your employer, nor an insurance company, nor even your relatives will learn about the data you record in Niebo Diary Dreams, or the information you receive in the App, unless you tell them about it yourself. We take all reasonable and appropriate measures to protect your Personal Data from loss, theft, misuse, or unauthorized access.

We ensure the inviolability of children’s confidential information

That is why, in order to use Niebo Diary Dreams, you must be at least 13 years old (at least 16 years old for EU residents). We intentionally do not collect information about children and do not allow the app to be used by those under 13 years old (16 years old for EU residents). In addition, some features of the App may be unavailable to users under 18 years old.

You can always contact us for help

We believe in transparent and open dialogue, so we strongly recommend that you contact our support service if you have any questions about this policy, the way your Personal Data is collected or processed, or any other questions related to our Privacy Policy.

Contact on Telegram.

1. Your Personal Data and Information We Collect

Personal Data You Provide to Us Directly

General Information. When you register to use the Application, we may collect the following Personal Data about you:

• name;

• email address;

• gender;

• date of birth;

• password or access code;

• place of residence and related location information;

• identity document (for limited purposes).

Health and Well-being. By using the Application, you may provide personal information (collectively, “Personal Data”), such as:

• events in your personal life;

• your emotional and mental state;

• other information about your well-being and related activities (including data about your personal life).

Personal Data We May Collect Automatically

When you access or use the Application, we may automatically collect the following data:

• device information:

  • device model;

  • information about the operating system and its version;

  • unique device identifiers (e.g., IDFA);

  • mobile network information;

  • information about the device’s storage systems.

• location information:

  • IP address;

  • time zone;

  • information about your mobile service provider;

• application usage data, including the following:

  • frequency of use;

  • sections of the Application that you visit and the features you use;

  • patterns of use of the Application;

  • interest in certain features.

Data from external sources. We may use third-party tools, such as Appsflyer, that provide certain identification data, which is subsequently used to customize and personalize the Application for you. We may also use this data to collect statistics and analytics.

2. How we use your Personal Data

Like any law-abiding organization, we will not collect and use your Personal Data without first notifying you or having good reason to do so. Therefore, in order to process your Personal Data, we need to have any valid ground or a so-called “legal basis”.

Depending on the situation, we will process your Personal Data on the following legal grounds:

• Your consent. Your permission to process the Personal Data that you provide to us on the registration screen or at any other appropriate moment, if necessary;

• Your contractual relationship with us. We may need to process Personal Data in order to provide access to the Application and its services, for their installation and further use;

• Legitimate interest. We have the right to process some of your personal data for commercial interests and to obtain broader social benefit;

• Legal obligation. We may be obligated to process some of your Personal Data on the basis of and in fulfillment of the requirements of applicable law and relevant regulations.

Below is a description of the main type of processing of your Personal Data, and the corresponding legal basis (with key examples provided):

2.5. Use of Data for Artificial Intelligence Training

We do not transfer or provide access to your Personal Data for training artificial intelligence and machine learning systems, unless otherwise expressly provided in a separate agreement with you.

Your data is used exclusively for the purposes specified in this Privacy Policy and is not used for training, fine-tuning, or improving third-party algorithms, including, but not limited to: OpenAI, Google AI, Anthropic, and other developers of AI systems.

In the event that we plan to use depersonalized aggregated data for scientific research or to improve our own algorithms, we ensure full anonymization that excludes the possibility of identifying your identity.

Processing Principles

Data minimization and purpose limitation. We will not process Personal Data in any way incompatible with the purposes for which the data was collected or for which you subsequently gave your consent, and we will not collect Personal Data that is not required for the specified purposes. For any new processing purpose, we will request your separate explicit consent.

No Sale of Personal Data. Under no circumstances will we sell, lend or disclose your Personal Data. We may provide only some of your Personal Data to our service providers in the cases and for the purposes strictly defined in this Privacy Policy. We will also not use information obtained as a result of your use of Apple HealthKit and Google Fit for advertising or similar services, and we will not sell it to advertising platforms, data brokers or information resale entities.

3. Your privacy rights

It does not matter which country or region you are from. We grant you broad rights concerning the privacy of your Personal Data.

What exactly are these rights?

Correction of Personal Data.

If you believe that your Personal Data is inaccurate, you may ask us to correct it.

Restriction of processing.

You also have the right to request restriction of the processing of your Personal Data if you contest its accuracy. In that case, we need some time to verify it.

Rights to information and access to your Personal Data (including data in a portable format).

The Application gives you the ability to access Personal Data in the Application. You have the right to request information about what Personal Data we hold about you, to access your Personal Data and to obtain a copy of it, including in a structured, portable format (.json). Where necessary, in accordance with the requirements of applicable law, we undertake to notify you of any breaches concerning your Personal Data.

Deletion of your Personal Data.

You may ask us to delete Personal Data if you withdraw your consent to processing or believe that such processing is contrary to applicable law, as well as in certain other cases. Please note that the deletion of certain Personal Data may affect the effectiveness of your use of the Application.

Right to object to the processing of Personal Data.

In some cases, you have the right to object to the processing of your Personal Data, for example, if we process it on the basis of legitimate interest. To do so, contact us at realunivers573@gmail.com.

How to exercise your privacy rights

Write to us at realunivers573@gmail.com to exercise any of your privacy-related rights.

We will ensure the fulfillment of such rights within 30 days from the moment of receiving the request. In some cases, we may need up to 90 days for this, for example, to fully delete your Personal Data stored in our backup systems. If we need additional time, we will certainly inform you of this and explain the reasons for the delay.

Additional information

Please keep in mind that if we receive a vague request, we may contact the user to better understand their motivation and the content of the request. We may also refuse to fulfill requests if they are clearly unfounded or excessive (repetitive).

In addition, in some cases we may require you to confirm your identity. As a rule, we verify that the request comes from the same email address that you provided when registering in the Application. In case of doubt, we may ask you to undergo additional verification. This will allow us to ensure that fulfilling your request does not violate the rights of third parties.

In accordance with applicable law, you may have the right to file a complaint with your local Personal Data protection supervisory authority about any of our actions (including in relation to your privacy rights) that, in your opinion, do not meet the requirements of the relevant laws. However, if you believe that we are doing something wrong, first let us know at realunivers573@gmail.com . We care about preserving the privacy of your personal life and want to make sure that we have done everything possible to resolve your concerns.

4. Processing of your Personal Data by third parties

We will not transfer your Personal Data to third parties, except in the cases listed below.

Data processing within the framework of the Niebo ltd new user acquisition program and maintaining communication with existing users

We may transfer some of your Personal Data not related to your dreams to AppsFlyer — a mobile marketing platform that processes your Personal Data in accordance with our instructions. By cooperating with AppsFlyer and its integrated partners, we can attract an audience similar to you on various platforms and tell them about the App, so that as many people as possible get an opportunity for self-discovery.

If we need to transfer your Personal Data for the same purposes to other platforms not provided for by this document, we will ask for your consent. Based on and in fulfillment of the relevant legal requirements, we are obliged to obtain your consent to the transfer of your data not related to dreams to AppsFlyer and its integrated partners.

1. You become a user of Niebo ltd and we begin transferring exclusively the following Personal Data:
   a) Technical identifiers: IP address (which may also provide general information about your location), User agent, IDFA (identifier for advertisers), Android ID (on Android devices), Google advertising ID, user-provided user ID, and other similar unique technical identifiers;
   b) your age group;
   c) your subscription status;
   d) the fact that the App was launched.

2. The application sends your data to the AppsFlyer platform, which analyzes it and provides us with reports and information on how to optimize our advertising campaigns.

3. At the same time, AppsFlyer sends your data to some of its integrated partners (e.g., Pinterest, Google Ads, Apple Search Ads, the FB marketing network and some other partners) to find you or people like you on various platforms, including social media sites. These integrated partners analyze your data and show relevant information about the Application to people who may be interested in it, or remind you to revisit the Application if you stopped using it some time ago.

4. This is exactly how you and new users learn about Niebo ltd, begin to understand your own motivations, and engage in self-development. By giving your consent to the use of the Niebo ltd application, you contribute to the development of the Niebo ltd community.

Detailed information about AppsFlyer is available here and about the partners — here

Opt-out options. You may at any time withdraw your consent or, depending on the circumstances, refuse the transfer of your Personal Data in accordance with this subsection by using one of the following options:

• By contacting us at realunivers573@gmail.com ;

• By changing your device settings in iOS or Android and refusing to provide your IDFA or Android advertising identifier.

Processing to ensure the functioning of the Application

We engage processors to perform specific operations with your Personal Data on our behalf.

Processors are companies that help us maintain the operation of the Application, ensure our communication with you, or perform other actions related to the Application. They may process certain Personal Data on our behalf in order to achieve purposes related to the functions of the Application and the corresponding actions. Processors act exclusively on our instructions and process only the scope of Personal Data specified by us. We bear full responsibility for any actions and omissions of our processors and undertake to enter into formal data processing agreements with them to the extent provided by applicable law.

Aggregated Information

Sometimes we may aggregate, anonymize, or de-identify your Personal Data in such a way that it cannot be used to identify you. Such data is no longer personal. We may share such data with our partners or research institutions. For example, we may share general demographic information about age and aggregated statistics about certain actions or symptoms that were derived from data collected to identify patterns among users, including in articles, blogs, and scientific publications. The sharing of such data contributes to the successful conduct of scientific research in the field of psychology.

Information You Post

The Application contains several community sections, such as “secret chats,” where users with similar interests can exchange information and support each other.

Any information (including Personal Data) that you share in any section of the online community or in online discussions is open to users of the Application. You should carefully consider everything before posting any Personal Data on a public forum. Third parties may see, receive, or collect the information you post and use it in ways that we cannot control or predict, including to contact you for unintended purposes.

In addition, posting your Personal Data in “secret chats” may violate the provisions of the “Secret Chats Terms of Use.” If you have mistakenly posted Personal Data in our community sections and want it to be deleted, you can send us an email, as specified below, with a request to delete that data.

Special Circumstances

We may also transfer some of your Personal Data in the following special circumstances:

• in response to judicial requests, court orders, or legal proceedings to the extent permitted by law and in accordance with the restrictions provided therein (including to satisfy national security requirements or requests from law enforcement agencies);

• when disclosure of information is required to maintain the security and integrity of the Application or to protect the safety of any user or the safety of others in accordance with applicable law. In such cases, we may also delete some of your Personal Data (for example, reset your password to prevent unauthorized access);

• when disclosure is requested by the user who entered the Personal Data, or their permission for this has been obtained;

• in the event that the Company undergoes a period of transformations, such as a merger, divestiture, acquisition, liquidation, or sale of all or part of its assets, your information will in most cases be part of the transferred assets.

5. Storage of Personal Data

When you use the Application

We will store your Personal Data while your account is active or as needed to provide you with the Services, and only for as long as it serves the processing purposes specified in Section 2 of this Privacy Policy. You may delete your Personal Data at any time in accordance with the Privacy Policy.

After you stop using the Application

If you decide to delete the Application, deactivate your account, or your account becomes inactive for some time, we will store your Personal Data for a reasonable period after its deactivation in case you decide to reactivate the Services.

The Application reflects several different periods of the user’s life; therefore, retaining your data is necessary in some cases to enable the effective use of other features of the Application (for example, when switching to “User Archive” mode).

You should know that we may retain certain Personal Data and other information after your account has been closed or deleted, if this is necessary to comply with legal obligations, resolve disputes, and enforce our agreements.

6. Protection of Personal Data

General Protection Measures

We take all reasonable and appropriate measures to protect all collected Personal Data from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the nature of the Personal Data we process and the risks associated with the special categories of Personal Data we collect (information about dreams). To protect your Personal Data, we use, among other things, the following information security measures:

• Pseudonymization and tokenization of certain categories of your Personal Data;

• Encryption of your Personal Data during transmission and during storage;

• Systematic vulnerability scanning and penetration testing;

• Data integrity protection;

• Organizational and legal measures. For example, our employees have different levels of access to your Personal Data, and access to it for certain purposes necessary to ensure the uninterrupted operation of the Application is granted exclusively to those employees who are responsible for data management within the framework of their job duties. We impose strict liability on our employees for the disclosure, alteration, destruction, misuse of your Personal Data, and unauthorized access to it.

• Conducting periodic assessments of the impact of data protection to ensure that the Application fully complies with the principles of “privacy by design,” “privacy by default,” and other standards. We also undertake to conduct a privacy review in the event of a merger or acquisition of the Company.

Remember that you can ensure the security of your information by choosing and protecting your password properly, not sharing it with others, and not allowing them to use your mobile device. Keep in mind that no security system is perfect, and therefore we cannot guarantee the absolute security of the Application or the absence of risks that your information will be intercepted during its transmission to us.

Security Breach

If we learn of a breach of security systems, we may either publish a corresponding notice or attempt to notify you by email and will take reasonable measures to address the breach in accordance with applicable laws and this Privacy Policy. If we become aware of a potential breach of confidentiality of Personal Data, as well as other actions mentioned in Section 3 of the Privacy Policy (for example, notifying you in certain cases), we will also take certain actions to address the breach, including, among other things, logging you out of your account on all devices, resetting the password (by sending you a temporary password), and taking other reasonably necessary actions.

If you want to report a data security breach in the app, write to us at realunivers573@gmail.com

7. Children’s Privacy

General age restriction. We are committed to protecting the privacy of children. The App is not intended for children, and we do not knowingly collect information about children under the age of 13. The App does not collect Personal Data from persons who, to the Company’s knowledge, have not yet reached the age of 13. If you are aware that the App is being used by a person under the age of 13, contact us at realunivers573@gmail.com , and we will take the necessary steps to delete the relevant information and/or account.

Age restriction for residents of the European Union. In accordance with legal requirements, you must be at least 16 years old to use the App. Use of the App within the European Union by persons under the age of 16 is prohibited. If you are aware that the App is being used by a person under the age of 16, contact us at realunivers573@gmail.com , and we will take measures to delete the relevant information and/or account.

8. Procedure for informational interaction with you

We may from time to time contact you by email or by other means (for example, through pop-up windows or push notifications) to inform you about products, services, offers, promotions, rewards, and events offered by us and others, and to provide news and information that we think will be of interest to you.

Opt-Out Options. You can always opt out of receiving emails by clicking the “Unsubscribe” link contained in each such email. Opting out of receiving such emails or notifications will not result in you no longer receiving important service-related emails that are necessary for using the App. Where provided for by applicable law, we may ask certain users to consent to such communications.

Please note that we may contact you and provide you with relevant information about products, services, offers, promotions, rewards, and events offered by us and others through third-party platforms (e.g., social media). See more information in the section “Data Processing within the Niebo ltd new user acquisition and ongoing user engagement program.” Please note that you can always opt out of such transfer and use of your Personal Data by contacting us at: realunivers573@gmail.com

9. Storage and International Transfer of Personal Data

The company is located in the United Kingdom, and actions regarding the Personal Data we collect are governed by UK law. Please note that UK law and the laws of other countries may not provide the same level of protection as the laws of your jurisdiction.

In addition, you agree that the collected Personal Data may be stored and processed in Germany, the United Kingdom, where the Company rents servers, or in any other country in which the Company or its affiliates, subsidiaries or agents have facilities, and, by using the Application, you consent to any such transfer of Personal Data outside your country.

10. Data Protection Officer (DPO)

If you need to contact our Data Protection Officer, please write to the email address: realunivers573@gmail.com or to the address indicated below.

11. Mailing

By registering on the site you give your consent to informational mailing on the site’s topics, with new promotions, actions, events and notifications about ongoing webinars.
You can unsubscribe from the mailing by the link in the email.

12. Contact Us

General Information

If you have any questions or concerns regarding privacy, you can contact us at:

Niebo ltd., Kemp House 128 City Road, London, EC1V 2NX, United Kingdom

Email: realunivers573@gmail.com

Contact in Telegram.

Resident of the EU, United Kingdom

In the CIS countries Belarus IP Antipenko NV UNP 491289402