Privacy Policy

Onaira ("the App", "we", "us", "our"), operated by Tranquil Mind Technology JSC, respects your privacy. This Privacy Policy explains what information we collect, how we use and share it, and the choices and rights you have. By using the App, you agree to this Policy.

Onaira is an entertainment app for watching vertical short-drama series, streamed from our servers one episode at a time. You do not need to create an account, sign in, or give us your name or email to use the App. Your watch history, saved series and preferences are stored locally on your device.

1. Information we collect

We collect only the information described below. Everything else the App does — remembering where you stopped watching, your saved series, your language choice, your viewing history — is stored only on your device and is never transmitted to us.

1.1 Information you provide

The App has no registration, no profile, no comments and no messaging, so there is nothing for you to submit. The only information you may send us voluntarily is what you include in an email to our support address.

1.2 Information collected automatically

1.3 What we do not collect

We do not collect your name, email address, phone number, postal address, contacts, calendar, photos, videos, camera or microphone input, precise GPS location, files, health data, financial account numbers, or web-browsing history outside the App. The App requests no camera, microphone, contacts, storage or location permission.

2. How we use information

We use the information above to:

• Provide and operate the App — deliver the catalogue, stream episodes, return search results, and keep the App stable.
• Show and measure advertising — display banner, in-feed, full-screen and app-open ads, limit how often you see the same ad, and measure whether ads were seen and clicked. Where you have consented (or where consent is not legally required), ads may be personalised based on identifiers and inferred interests.
• Attribute installs — understand which marketing channel brought you to the App, so we do not pay twice for the same install.
• Analyse and improve — understand which features and series people use, in aggregate, and decide what to build next.
• Prevent fraud and protect security — detect invalid ad traffic, install fraud, tampering with the App, and unauthorised access to our catalogue.
• Process and restore purchases — verify entitlements through Google Play Billing where the App offers paid features.
• Comply with law — meet legal, regulatory and enforcement obligations.

We do not use your information to make automated decisions that have a legal or similarly significant effect on you.

3. Third-party services

The App includes software from the third parties below. When the App runs, these services may receive some of the information described in Section 1 and process it under their own privacy policies. We recommend reviewing them.

Not every advertising partner above is active at all times. Ad demand partners are enabled and disabled from our ad-mediation configuration, so the set of partners that actually receives data in a given session may be smaller than this list.

3.1 Advertising consent (EEA, UK and other consent regions)

If you are in the European Economic Area, the United Kingdom, Switzerland, or another region where consent is required for personalised advertising, the App shows a consent message the first time you open it, using Google's User Messaging Platform (UMP) and the IAB Transparency & Consent Framework. Your choice determines whether our advertising partners may use identifiers to personalise ads. If you decline, you will still see ads, but they will be non-personalised (contextual).

3.2 Controlling the advertising identifier

You can limit advertising tracking at the operating-system level at any time:

• Android: Settings → Google → All services → Ads → Delete advertising ID, or Reset advertising ID. Deleting the ID stops apps from receiving it.
• iOS: Settings → Privacy & Security → Tracking → turn off Allow Apps to Request to Track.

You can also opt out of Google's personalised advertising at https://adssettings.google.com and use the industry opt-out tools at https://optout.aboutads.info and https://www.youronlinechoices.eu.

4. How we share information

We do not sell your personal information for money. We do not operate a data brokerage, and we do not disclose your information to anyone except as described here.

We share the information in Section 1 with:

• The service providers and advertising partners listed in Section 3, for the purposes stated there.
• Legal and safety recipients — courts, regulators, or law-enforcement authorities where we are legally required to respond, or where disclosure is necessary to establish, exercise or defend legal claims, or to protect the rights, safety or property of our users, the public, or us.
• A successor entity — if we are involved in a merger, acquisition, financing, reorganisation or sale of assets, information may be transferred as part of that transaction. Any recipient remains bound by this Policy or a policy at least as protective, and we will post notice of any material change.

United States "sale" and "sharing" caveat. Some U.S. state privacy laws, including the California Consumer Privacy Act as amended by the CPRA, define "sale" and "sharing" broadly enough to include disclosing identifiers to advertising partners for cross-context behavioural advertising, even where no money changes hands. Because the App shows personalised advertising where permitted, our use of advertising identifiers may be treated as a "sale" or "sharing" under those laws. You can opt out as described in Sections 3.1, 3.2 and 7.2.

We do not knowingly share the sensitive personal information of any user, and we do not share information about known minors for cross-context behavioural advertising.

5. Legal bases for processing (EEA and UK)

If you are in the EEA or the UK, we rely on the following legal bases under the GDPR and UK GDPR:

6. Data retention

We keep information only as long as necessary for the purposes described in this Policy, or as required by law.

• Analytics data held in Firebase is retained according to our configured retention setting, after which it is deleted or aggregated. Aggregate, non-identifying statistics may be kept indefinitely.
• Crash logs and diagnostics are retained for a limited period sufficient to diagnose and fix the underlying problem, typically no more than 90 days for detailed reports.
• Advertising and attribution identifiers are retained by the partners in Section 3 under their own retention schedules, which their policies describe.
• Purchase records are retained for as long as the entitlement may be restored and for the period required by tax and accounting law.
• On-device data — watch history, saved series, unlock state and preferences — remains on your device until you clear the App's data or uninstall the App. Uninstalling removes it.

7. Your rights and choices

7.1 Rights under the GDPR and UK GDPR

If you are in the EEA or the UK you have the right to: access the personal data we hold about you; rectify inaccurate data; erase your data; restrict or object to processing, including objecting to processing based on legitimate interests and to direct marketing; data portability; and to withdraw consent at any time without affecting the lawfulness of processing already carried out. You also have the right to lodge a complaint with your national data-protection authority.

7.2 Rights under the CCPA/CPRA and other U.S. state laws

If you are a resident of California or another U.S. state with a comprehensive privacy law, you have the right to: know what personal information we collect, use and disclose; access and obtain a copy of it; delete it; correct inaccurate information; opt out of the sale or sharing of your personal information and of targeted advertising; limit the use of sensitive personal information; and not be discriminated against for exercising these rights. You may use an authorised agent.

To opt out of the sale or sharing of your personal information for targeted advertising, use the advertising-identifier controls in Section 3.2 (deleting or resetting the advertising ID is the most effective and immediate opt-out for this App), or contact us as described below. The App does not respond to Global Privacy Control browser signals, because it is not a website.

7.3 Rights in other regions

Residents of Brazil (LGPD), Canada (PIPEDA), and other jurisdictions with comparable laws may have equivalent rights of access, correction, deletion, portability and objection. We honour valid requests from any region.

7.4 How to exercise your rights

Email contact@tranquilmind.co with your request.

Important — the App has no accounts. Because we never collect your name, email or any account identifier, we usually have no way to link stored data to you personally. To let us find and act on your data, please include in your email:

1. Your advertising ID (Android: Settings → Google → All services → Ads; iOS: available via privacy-focused utilities), and
2. Your device model and operating-system version, and
3. The approximate date you last used the App.

Without an identifier we may be unable to locate any data associated with you, and we will tell you so rather than act on the wrong records. We will respond within the time required by applicable law — generally one month under the GDPR and 45 days under the CCPA, each extendable where the law permits. We do not charge a fee unless a request is manifestly unfounded or excessive.

You can also delete everything the App stores locally at any time by clearing the App's data in your device settings or uninstalling the App.

8. Children's privacy

Onaira is intended for users aged 16 and over. The App contains dramatised content with mature themes and is not directed to children.

We do not knowingly collect personal information from children. Specifically:

• The App is not distributed through the Google Play Designed for Families programme, and its store listing declares a target audience of 16-17 and 18+.
• We do not knowingly collect personal information from children under 13 (or under 16 where local law sets a higher age of digital consent, such as in parts of the EEA), in the sense of the U.S. Children's Online Privacy Protection Act (COPPA) and equivalent laws.
• If we learn that we have collected information from a child below the applicable age, we will delete it promptly.

If you are a parent or guardian and believe a child has used the App and that we hold their information, contact contact@tranquilmind.co and we will investigate and delete what we find.

9. International data transfers

We operate from Vietnam, and the third parties in Section 3 operate globally, including in the United States, the European Union, Singapore and elsewhere. Your information may therefore be transferred to, stored in, and processed in countries whose data-protection laws differ from those of your country.

Where we or our partners transfer personal data out of the EEA, the UK or Switzerland, that transfer is made under an appropriate safeguard — most commonly the European Commission's Standard Contractual Clauses (and the UK Addendum or the UK International Data Transfer Agreement, where applicable), or a valid adequacy decision or certification. Details of the specific mechanism a given partner relies on appear in that partner's privacy policy, linked in Section 3.

10. Data security

We use reasonable technical and organisational measures to protect information:

• All data transmitted by the App is encrypted in transit using HTTPS/TLS.
• Requests to our catalogue service carry an integrity token issued through Firebase App Check and Play Integrity, so tampered or repackaged copies of the App are rejected.
• The App includes runtime application self-protection (freeRASP) that detects tampering, repackaging and unsafe runtime environments.
• Access to analytics, crash and configuration consoles is limited to personnel who need it.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a personal-data breach that is likely to result in a risk to your rights, we will notify the relevant supervisory authority, and you, as and where applicable law requires.

11. Third-party content

Onaira streams drama series supplied by third-party content providers, and displays advertising supplied by the advertising partners in Section 3. We do not control, endorse or assume responsibility for the content of third-party series, advertisements, or any website an advertisement links to. Opening an advertisement or a link takes you outside the App, where this Policy no longer applies and that destination's own terms and privacy policy govern. Please review them before providing any information.

The App also includes a share feature that hands a link to your device's own share sheet. When you choose an app to share to, that app's privacy policy governs what happens next; we receive nothing from that action.

12. Changes to this Policy

We may update this Policy to reflect changes in the App, our partners, or the law. When we do, we will change the "Last updated" date at the top and publish the revised Policy at https://policy.tranquilmind.co/onaira/privacy. If a change is material — for example, if we begin collecting a new category of data or add a new category of recipient — we will provide prominent notice in the App or seek your consent where the law requires it. Your continued use of the App after a revised Policy takes effect means you accept it. We encourage you to review this page periodically.

13. Contact us

Tranquil Mind Technology JSC
No. 3, Alley 98, Vu Trong Phung Street, Thanh Xuan Ward, Hanoi City, Vietnam
Email: contact@tranquilmind.co

For privacy requests, please write "Privacy request" in the subject line and include the details listed in Section 7.4.