PLEASE READ THIS PRIVACY POLICY CAREFULLY By using the LU mobile application (the “App”) or the website located at https://lu-app.ru (the “Website”) (App and Website individually referred to as a “LU Service” or collectively as the “LU Services”) or otherwise indicating your acceptance (e.g. by clicking tick-box or bottom “agree” or “continue”), you agree to the following terms of our Privacy Policy, which will bind you at all times and in whatever manner you use the LU Services. The app is made to help you feel happier by showing you ways to take care of your mental health and well-being. The app does not tell you if you have a disease or condition, or how to treat it. The app gives general advice for your mental health and well-being. 1. What Information We Collect and Use When you use the LU services, we collect the following information. You control the information you share with us. We design our app to collect as little personal data as possible to keep your data safe and protect your privacy. This means there is less risk of your information being misused. When you share information with us, we are responsible for taking care of it. Information provided by you. Information about you. This includes things like your nickname, age-range, gender, pronouns, or identifiers you may voluntarily reveal about yourself. Conversation data. This covers what you type in messages, your challenges, preferences, feelings, moods, thoughts, task lists, and safety information. Correspondence data. If you email us, you might share personal data like your name, email address, home address, the company you are part of, your job title, and what you talk about in the message. Feedback data. When we ask for your thoughts on our app and services, we gather your contact info and some basic details about you. When you visit our website or social media accounts or our web pages. When you visit our website or web pages or just reach out to us for business purposes, we will collect the following information from you. Correspondence data: If you contact us, you might share personal data like your name, email address, home address, the company you are part of, your job title, business contact details and what you talk about in the message. Cookie Information. We and our third-party providers collect information about your website use via cookies or similar technologies. Information could include but not limited to browser type, browser language, operating System, language settings, web page views and the link clicks, campaign clicks, IP address. Usage Data: Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device. Information Collected while Using the Application While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission: - Pictures and other information from your Device's camera and photo library We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device. You can enable or disable access to this information at any time, through Your Device settings. 2. How We Use Your Information We need to follow data protection laws that make sure we look after your personal data properly. Here is how and why we might use it: Consent: Sometimes, we ask you if it is okay to use your personal data. You can always change your mind later if you decide you do not want us to use it anymore by writing to us Contract Performance: When you use our app or services, we might need some of your personal data to provide our services and make sure everything works properly. Legitimate Interests: We or someone we trust, might use your personal data to keep our services safe from fraud or security problems. We might also use it to make our services better. Legal Obligation: Sometimes, we need to use your personal data to follow the law or to protect our company and the people who provide the services. The LU may use Personal Data for the following purposes: To provide and maintain our Service, including to monitor the usage of our Service. To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user. For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service. To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation. To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information. To manage Your requests: To attend and manage Your requests to Us. For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred. For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience. Retention of Your Personal Data The LU will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The LU will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods. Transfer of Your Personal Data Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information 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. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The LU will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information. Delete Your Personal Data You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. Our Service may give You the ability to delete certain information about You from within the Service. You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us. Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so. Disclosure of Your Personal Data Business Transactions If the LU is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy. Law enforcement Under certain circumstances, the LU may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Other legal requirements The Company may disclose Your Personal Data in the good faith belief that such action is necessary to: - Comply with a legal obligation - Protect and defend the rights or property of the Company - Prevent or investigate possible wrongdoing in connection with the Service - Protect the personal safety of Users of the Service or the public - Protect against legal liability Security of Your Personal Data The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. Children's Privacy Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers. If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information. Age limitation for EEA/UK individuals. You must be at least 16 years old in order to use LU Services. We do not allow use of LU by EEA individuals younger than 16 years old. If you are aware of anyone younger than 16 using LU, please contact us by e-mail: privacy@lu-app.ru, and we will take the required steps to delete the information provided by such persons. Links to Other Websites Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. Changes to this Privacy Policy We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Contact Us If you have any questions about this Privacy Policy, You can contact us: By email: privacy@lu-app.ru