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Privacy Policy

1. Introduction

Welcome to LutinApp ("we," "our," or "us"). We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website https://lutinapp.com or use our mobile application (collectively, the "Service").

We operate in accordance with the General Data Protection Regulation (GDPR) for European users and applicable US state and federal laws, including the California Consumer Privacy Act (CCPA).

2. Information We Collect

A. Personal Data

We may collect personally identifiable information that you voluntarily provide to us, such as:

  • Identity Data: Name, username.
  • Contact Data: Email address, phone number.
  • Financial Data: Payment method details (processed by third-party payment processors; we do not store full credit card numbers).

B. Derivative & Usage Data

When you access the Service, our servers automatically collect information, including:

  • IP address and browser type.
  • Operating system and device name.
  • Access times and pages viewed.
  • For Mobile: Device ID, model, and manufacturer.

C. Cookies and Tracking Technologies

We use cookies, web beacons, and tracking pixels to customize the Site and improve your experience.

  • Europe (GDPR): We ask for your explicit consent before placing non-essential cookies.
  • USA: You may opt-out of cookies via your browser settings.

3. How We Use Your Information

We use your data to:

Create and manage your account.

Process payments and refunds.

Email you regarding your account or order.

Monitor and analyze usage and trends to improve the Service.

Prevent fraudulent transactions and theft.

Comply with legal obligations.

4. Legal Basis for Processing (GDPR - Europe)

If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal information described above depends on the Personal Information concerned and the specific context in which we collect it:

  • Contractual Necessity: To provide the Service to you.
  • Legitimate Interests: For our business improvement and security.
  • Consent: For marketing communications and non-essential cookies.

5. Sharing Your Information

We may share information with:

  • Service Providers: Third parties that perform services for us (e.g., AWS/Google Cloud for hosting, Stripe/PayPal for payments).
  • Legal Requirements: If required to do so by law or in response to valid requests by public authorities.
  • Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition.

6. International Data Transfers

Your information, including Personal Data, may be transferred to—and maintained on—computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

  • For European Users: If we transfer data to the US, we rely on standard contractual clauses (SCCs) or the Data Privacy Framework to ensure adequate protection.

7. Your Data Protection Rights

A. For EEA/UK Users (GDPR)

You have the right to:

  • Access: Request copies of your personal data.
  • Rectification: Request that we correct any information you believe is inaccurate.
  • Erasure: Request that we erase your personal data ("Right to be forgotten").
  • Restrict Processing: Request that we restrict the processing of your personal data.
  • Data Portability: Request that we transfer the data that we have collected to another organization, or directly to you.

B. For US Users (California - CCPA/CPRA)

Residents of California have the right to:

  • Request disclosure of the categories and specific pieces of personal data we have collected.
  • Request deletion of personal data.
  • Opt-out of the "sale" of personal data (LutinApp does not sell personal data for money).
  • Non-discrimination for exercising these rights.

8. Data Retention

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, or to comply with legal obligations.

9. Children's Privacy

Our Service does not address anyone under the age of 13 (USA) or 16 (Europe). We do not knowingly collect personally identifiable information from children. If we become aware that we have collected Personal Data from a child without verification of parental consent, we take steps to remove that information.

10. Contact Us

If you have questions about this Privacy Policy, please contact us: