Lublu

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LUBLU – GLOBAL PRIVACY POLICY

Last Updated: 18 February 2026

1. Introduction

This Privacy Policy explains how Lublu (“Lublu,” “we,” “us,” or “our”) collects, uses, processes, stores, and protects personal information when you access or use the Lublu mobile application, website, and related services (collectively, the “Services”).

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.

Lublu acts as the data controller for personal information processed in connection with the Services.

2. Scope

This Privacy Policy applies globally to all users of the Services, regardless of location.

Where local laws provide additional rights or impose specific obligations, those rights and obligations apply automatically to the extent required by applicable law.

3. Information We Collect

We may collect and process the following categories of information:

Information You Provide Directly

  • Account registration information (such as email address)
  • Profile details
  • Journal entries, shared “moments,” messages, and uploaded images
  • Communications with support

Automatically Collected Information

  • Device information
  • App usage data
  • Interaction data
  • Log data
  • Subscription status and transaction metadata

Information From Third Parties

  • Payment confirmations from app store platforms
  • Analytics and hosting providers acting on our behalf

We collect only information necessary to operate, secure, and improve the Services.

4. Legal Bases for Processing

We process personal information under one or more of the following lawful bases, depending on your jurisdiction:

  • Performance of a contract (to provide the Services you request)
  • Legitimate interests (to improve, secure, and operate the Services)
  • Compliance with legal obligations
  • Your consent, where required
  • Protection against fraud, abuse, or unlawful conduct

Where consent is required, you may withdraw it at any time, subject to legal and operational limitations.

5. How We Use Information

We use personal information to:

  • Provide and maintain the Services
  • Enable journaling, image sharing, and partner features
  • Process subscriptions through Apple’s in-app purchase system
  • Improve performance and functionality
  • Monitor misuse and enforce our Terms
  • Prevent fraud, abuse, and security incidents
  • Comply with legal obligations

We do not sell personal information.

We do not use personal content for advertising purposes.

6. User-Generated Content

The Services allow users to upload and share text and images.

You acknowledge and agree:

  • You are solely responsible for the content you upload or share.
  • You must have all necessary rights to upload such content.
  • Content shared with another user may be copied, saved, captured, or redistributed by that user.
  • Lublu cannot technically prevent screenshots or external copying.
  • Lublu is not responsible for how other users handle shared content.

We may remove content that violates our Terms or applicable law.

Deletion of content from your account does not guarantee deletion of copies retained by another user.

To the fullest extent permitted by law, Lublu disclaims responsibility for user misuse of shared images or journals.

7. Content Moderation and Enforcement

We may monitor, review, restrict, or remove content at our discretion to:

  • Enforce platform safety
  • Comply with legal obligations
  • Prevent abuse or unlawful activity

We are not obligated to monitor all content.

8. Data Sharing

We may share personal information only in the following circumstances:

  • With service providers acting on our behalf (hosting, analytics, infrastructure)
  • With app store platforms for subscription processing
  • When required by law or valid legal request
  • To prevent fraud, abuse, or security threats
  • In connection with a merger, acquisition, or corporate restructuring

All service providers are required to process information under contractual safeguards.

We do not sell personal information.

9. International Data Transfers

Because Lublu operates globally, personal information may be transferred and processed in jurisdictions outside your country of residence.

Where required by law, we implement appropriate safeguards for cross-border data transfers.

By using the Services, you acknowledge that data may be processed internationally.

10. Data Retention

We retain personal information only as long as necessary to:

  • Provide the Services
  • Fulfill contractual obligations
  • Comply with legal requirements
  • Resolve disputes
  • Enforce agreements

We may delete inactive accounts and associated data at our discretion.

We are not obligated to retain user content indefinitely.

11. Your Rights

Depending on your jurisdiction, you may have rights to:

  • Access your personal information
  • Correct inaccurate information
  • Request deletion
  • Restrict or object to processing
  • Request data portability
  • Withdraw consent
  • Opt out of certain data uses
  • Request information about categories of data collected and shared
  • Request disclosure of third-party categories receiving data
  • Not be discriminated against for exercising privacy rights

We will respond to verified requests in accordance with applicable law.

We may request identity verification before fulfilling requests.

Certain data may be retained where legally permitted or required.

12. Children’s Privacy

The Services are not intended for children under the age required by applicable law in their jurisdiction.

We do not knowingly collect personal information from children where prohibited.

13. Data Security

We implement reasonable administrative, technical, and organizational safeguards designed to protect personal information.

However:

  • No system is completely secure.
  • No transmission method guarantees absolute security.

You acknowledge that use of the Services is at your own risk.

14. Subscriptions and Payment Data

Subscriptions are processed through Apple’s in-app purchase system.

Lublu does not directly store full payment card information.

Subscription management, renewal, and cancellation are handled through your app store account settings.

15. Automated Decision-Making

We do not use automated decision-making systems that produce legally significant effects without human oversight.

16. Changes to This Policy

We may update this Privacy Policy at any time.

Material changes will be reflected by updating the “Last Updated” date.

Continued use of the Services constitutes acceptance of the updated Policy.

17. Limitation of Liability

To the fullest extent permitted by applicable law:

Lublu shall not be liable for:

  • Unauthorized access resulting from user actions
  • Screenshots or redistribution of shared content
  • Emotional, reputational, or relational harm
  • Loss of user-generated content
  • Data exposure caused by another user
  • Indirect, incidental, consequential, special, or punitive damages

Nothing in this Privacy Policy excludes liability where exclusion is prohibited by law.

18. Contact

Requests regarding privacy rights or data inquiries may be submitted through the contact information provided within the application.