Privacy Policy

Last Updated: June 5, 2026

This Privacy Policy describes how Lumora Interactive Entertainment Limited ("we", "us", or "our") collects, uses, and handles your information when you use our mobile application ("App").

1. Information We Collect

1.1 Device and Usage Information

We automatically collect certain technical information when you interact with our App:

Device model, manufacturer, and hardware specifications
Operating system type and version
Unique device identifiers (such as IDFA, IDFV, or advertising IDs)
Mobile network information and preferred language settings
App usage statistics, session duration, and feature interactions
Crash logs, diagnostics, and performance data

1.2 Information You Provide Voluntarily

We collect information that you explicitly and voluntarily submit to us, which includes:

Feedback, support requests, or customer service correspondence.
User-generated content or preferences you input within the App.

1.3 Shipping Information for Promotional Rewards & Gifts

If you participate in our optional promotional campaigns, subscribe to eligible premium plans, or qualify to receive physical complimentary rewards (such as a complimentary smart hardware or body fat scale), we may request that you provide the following Personally Identifiable Information (PII):

Full Name
Phone Number
Physical Shipping Address (including street address, city, state/province, postal code, and country)

Important Note on Voluntariness: Providing this shipping information is completely optional and voluntary. It is not required to access or use the core digital features of our App (such as health tracking, AI guidance, or manual data logging). We will only prompt for this information after you explicitly opt-in and initiate a physical reward shipment request.

2. How We Use Your Information

We use the collected data for the following legitimate business purposes:

Provide, operate, and maintain the core functions of the App.
Improve, personalize, and optimize the App functionality and user experience.
Process, fulfill, ship, and deliver physical promotional gifts or rewards directly to your designated address.
Diagnose technical issues, monitor system stability, and patch crashes.
Analyze aggregate usage patterns to guide our product development.
Ensure the security and integrity of the App, preventing fraudulent or unauthorized activities.
Comply with applicable legal obligations, tax regulations, and accounting standards.

3. Information Sharing

We do not sell your personal information. We may share your data with trusted third parties only under the following circumstances:

Service Providers

We engage reputable third-party vendors to perform operational services on our behalf, including data analytics providers, cloud hosting services, and crash reporting tools.

Logistics and Fulfillment Partners

To successfully deliver your physical rewards or gifts, we will securely share your Full Name, Phone Number, and Physical Shipping Address with our contracted third-party logistics providers, warehousing partners, and global/local postal carriers (such as USPS, FedEx, DHL, or regional couriers). These partners are strictly bound by confidentiality agreements and are prohibited from using your data for any marketing or other unauthorized purposes.

Legal Requirements

We may disclose your information if required to do so by law, court order, or legal process, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.

Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of company assets, your information may be transferred as part of the transaction assets. We will notify you of any such change in ownership.

4. Data Security

We implement industry-standard technical, administrative, and organizational measures designed to protect your personal information against unauthorized access, loss, or alteration. However, please be aware that no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

5. Data Retention

We retain your personal data only as long as necessary to fulfill the purposes outlined in this Privacy Policy.

Specific Retention for Shipping Data: To minimize privacy risks, your Full Name, Phone Number, and Physical Shipping Address collected for promotional rewards will only be retained in our active secure systems for the duration required to guarantee successful delivery and resolve potential shipping disputes (typically deleted or completely anonymized within 90 days following delivery confirmation), unless a longer retention period is mandated by tax laws or financial auditing regulations.

6. Your Rights

Depending on your geographical location, you may have the right to:

Access the specific pieces of personal information we hold about you.
Request corrections or updates to inaccurate personal data.
Request the permanent deletion of your personal data from our active databases.
Withdraw your consent at any time (e.g., by opting out of promotional rewards).
Opt-out of all data collection instantly by uninstalling the App.

To exercise any of these rights, please contact us via the email address listed below.

7. Children's Privacy

Our App is not directed to or intended for children under the age of 13 (or under 16 in certain jurisdictions). We do not knowingly collect personal information from children. If we discover that a child has provided us with personal information, we will delete it immediately.

8. Third-Party Links and Services

The App may contain links to third-party websites or services. We are not responsible for the privacy practices, content, or data processing activities of those external third parties. We encourage you to read their respective privacy policies.

9. International Transfers

Our operations are global, and your information may be transferred to, stored, and processed in countries outside of your home jurisdiction (including Hong Kong, the United States, or other international server locations). These countries may have data protection laws that differ from those of your home country. By using the App, you consent to these transfers.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our operational practices or legal requirements. When we do, we will update the "Last Updated" date at the top of this page. We encourage you to review this policy periodically.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at:

Lumora Interactive Entertainment Limited
Email: info@lumorai.app
Address: RM26, 2/F, 118 Wai Yip Street, Kwun Tong, Kowloon, Hong Kong

12. California Privacy Rights (CCPA/CPRA)

For California residents, this section supplements our Privacy Policy under the California Consumer Privacy Act (CCPA), as amended by the CPRA:

Categories of Information Collected: In the past 12 months, we may have collected Identifiers (such as device IDs, IP address, Full Name, Phone Number, and Shipping Address).
No Sale or Sharing: We do not "sell" or "share" your personal information for cross-context behavioral advertising, nor do we disclose sensitive personal information for purposes other than providing the core services or fulfilling physical rewards.
Your Rights: You have the right to know what personal information we collect, request deletion, correct inaccurate data, and opt-out of any potential sharing without facing discrimination.

13. European Privacy Rights (GDPR)

For users residing in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, our processing of your personal data is governed by the General Data Protection Regulation (GDPR) and equivalent laws:

Legal Basis for Processing: We process your device data based on our Legitimate Interests (to improve and secure our product). We process your Name, Phone Number, and Shipping Address strictly based on your explicit Consent and for the Performance of a Contract (to deliver the reward you requested).
Your Rights: You have the right to access, rectify, or erase your data, the right to data portability, the right to restrict or object to certain processing, and the right to lodge a complaint with a local supervisory authority.