Privacy Policy

Last modified: June 10, 2024

At LUVIO MOBILE, we take the privacy of our users seriously. If you have any questions or concerns about our Privacy policy, please don't hesitate to contact us via our support form.

If you would like to opt-out of data usage, please select the "DO NOT USE MY DATA" option. For more information about how your data may be used for interest-based advertising, click here.

I. GENERAL TERMS

This is the Privacy Policy of LUVIO MOBILE ("we," "us," or "our"). The policy outlines our data protection practices and describes the types of information we may process when you use our mobile application, Messenger for WhatsApp & AI (the “App”, “our App”). This policy applies to all users who access our App (“Users”).

The term "personal data" or "personal information" refers to any information that relates to an identified or identifiable natural person.

Personal data refers to any information that pertains to a natural person who can be directly or indirectly identified, particularly through an identification number or by one or more unique factors related to their physical, physiological, mental, economic, cultural or social status.

We act as the data controller under the GDPR, unless otherwise specified.

FOR CALIFORNIA CONSUMER PRIVACY ACT OF 2018 (CCPA) PRIVACY NOTICE CLICK HERE

II. PROCESSED INFORMATION:

There are several categories of information that might be processed: (a) Functional data, (b) Payment Information, (c) Automatically Processed Data, (d) Contact information. Please refer to Section III to learn more details.

Children’s Privacy

Our App is designed for individuals who are 18 years old or older, and we do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not use or provide any information on this App or through any of its features. If we learn that we have collected personal information from a child under the age of 18 without verifiable parental consent, we will delete that information as soon as possible. If you believe we may have collected information from or about a child under 18, please contact us immediately.

III. THE PURPOSES OF PROCESSING DATA

We use your information for the following purposes:

• To provide the App and its services: We use your information to provide the App and its services to you. This includes processing functional information and automatically processed information to ensure that you can access and use the App as intended.

  (a) Functional data

  To fulfill our contractual obligations and provide the requested services we require functional data. This is absolutely necessary to guarantee the full functionality of the App.

  User Content: This includes any text or other content that you enter into the message field and send through the App (“Input”), as well as any text or other content generated by AI via the App (“Output”). You may use, share, and otherwise exploit your User Content for your own purposes, subject to your compliance with the rules and restrictions outlined in our Terms of Use. However, any use of User Content is solely at your own risk, and you assume all risks and responsibilities associated with such use. You are solely responsible for ensuring compliance with applicable laws when using User Content. Please note that we use third-party service providers, OpenAI, L.L.C., Anthropic Ireland, Limited and Anthropic, PBC, for processing and creating AI-generated User Content. We also engage the third-party service provider Phrasly LLC for the purposes of checking whether your text has been written by AI within the in-app feature “AI Detector”. Additionally, if you choose to try the “GPT + Internet” feature, your Input will be processed by our third-party service providers, Microsoft Corporation and Google LLC, in order to obtain Internet search results pertinent to your Input and update your Output accordingly. Please refer to Section IV to learn more about OpenAI, L.L.C.'s, , Anthropic Ireland, Limited’s, Anthropic, PBC’s, Microsoft Corporation’s and Google LLC’s privacy policies and practices.

  Contact Information: This includes your name, email address, and any other content you provide when contacting us via email or support form. We store and process this information using our cloud storage provider, Amazon.com, Inc. We use this information to respond to your inquiries, fulfill your requests, and provide you with requested services or communications.

  (b) Payment Information

  Our e-commerce provider, Apple, is responsible for securely processing and charging for in-app purchases, and for handling your personal information in a safe and secure manner. We do not have access to or use your credit or debit card information as this is processed as part of the contract between you and Apple. You may access the rules and policies for in-app purchases directly from the app stores. You can access the relevant rules and policies for "in-app" purchases directly from the app stores.

• To improve the App and personalize your experience: We use automatically processed information to analyze how users interact with the App, identify areas for improvement, and test new features and functionality. This helps us to continuously improve the App and provide a better service. We may use automatically processed information to personalize your experience within the App. For example, we may use this information to show you content that is tailored to your interests, or to suggest features or services that may be of interest to you.

  (c) Automatically Processed Data

  • Log file information. When you access the App, log file information is automatically generated and reported. Additionally, this information may be provided when you install the App on your device. Our analytics tools automatically record specific log file information when you use the App, such as the start and stop time and date of usage, and how you interact with the App.
  • Mobile Device Data, including “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by the third parties.Certain device identifiers are processed to improve the quality of customer support. We automatically process information about the device itself (type of device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, battery life, loading time, latency, framerate, device memory usage), information about the Internet connection (mobile carrier, network provider, network type, IP address, timestamp and duration of sessions, speed, browser), location-related information (IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, time zone, neighboring commercial points of interest (eg. “coffee shop”)), other device identifiers: e.g. user identifiers (if they are set up by the App’s developer). In case you submit a support request, the device identifiers to be processed additionally comprise your device ID (identification number of your mobile device) and your user ID (the number assigned to the App upon its installation at your device). The processing of user ID and device ID enables us to review your support request in a more detailed manner as applied to your particular case. This therefore may allow us a) to expedite your support request (e.g. complete troubleshooting); and, if needed b) to approach you with a tailor-made solution for fixing the issue being of concern for you.
  • Cookies and similar technologies. When you use the App, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information which is downloaded to your device when you access the App. The text file is then sent back to the server each time you use the App. This enables us to operate the App more effectively. For example, we will know how many users access specific areas or features within our App and which links or ads they clicked on. We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that are of interest to you. We may ask advertisers or other partners to serve ads or services to the App, which may use cookies or similar technologies.
  • Information about the applications. Name, API key (identifier for application), version, properties of our App can be reported for automated processing and analysis. Some services also record the list of applications and/or processes which are installed or run on your device.
  • Ad-related information. Information related to advertisements that you view, such as the time and date the ad is shown, whether you clicked on it or if it resulted in a conversion event, the content and type of the ad (such as text, image, or video), where it was displayed in the App, and your response to the ad, may be reported.
  • In-App Events. Analytics tools integrated into our App automatically capture and store data related to your in-App activities, such as completing tutorial steps, making in-app purchases or payments, triggering custom events, progressing through levels or stages, and any opt-out mechanisms used to limit data processing.

  The data is processed via third-party automatic data processing technologies, such as advertising or analytics tools, to analyze certain information sent by your device through our App (e.g., Identity For Advertisers for iOS devices/ Advertising ID or Android ID for Android devices), with your permission. This data is typically non-personal, meaning it cannot be directly linked to any specific individual, and we only access it in an aggregated form. However, some of these integrated tools (please see Section V for a list) may conduct automated processing of your personal data, including profiling. Profiling involves any form of automated processing of personal data used to evaluate certain personal aspects relating to you, particularly to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (please refer to the list of data below). Automatic data processing technologies will start processing information as soon as you allow our App to track your activity. You may withdraw your permission at any time by checking the opt-out options in Section VIII below.

  Please note that we do not have control over the information provided automatically to advertising or analytics tools, and therefore cannot take responsibility for the processing of such information. It is important to be aware that some services engage in personal data profiling and may obtain information related to your personality or device through technologies that are not under our responsibility. If your user ID is linked to your Facebook account, Facebook may use your device information in conjunction with categorized data that have already been recorded in its databases, such as your age, gender, or other demographic indicators. We do not supervise, control, or guarantee how third parties handle your personal data that may be collected through means other than our app. If you have any questions about the disclosure of your personal information, please direct them to the third parties involved (refer to Section V).

• To communicate with you: We may use your contact information to communicate with you about the App, such as to provide you with updates, respond to your inquiries, and provide customer support.

  (d) Contact Information: your name, your email address and data that you might enter and upload as part of your support request.

• To enforce our policies and protect our rights: We may use your information to enforce our policies and protect our rights, including investigating and preventing fraud, spam, or other unauthorized activity, and complying with legal obligations.

If we use your information for any other purpose not listed here, we will notify you and obtain your consent as required by applicable law.

VI. HOW LONG WE KEEP AND USE YOUR DATA

We will keep your personal information only for as long as necessary to provide the functional service of the App and to fulfill our legal obligations. If you decide that you no longer want us to use your information that we physically access and store, you can request that we delete your personal information and close your account.

However, some data may still be stored for a limited period of time (but no longer than necessary) if required by law (such as for taxation, accounting, or auditing purposes) or to maintain the safety and backup of data, prevent fraud, or other malicious acts.

V. SHARING OF DATA

When we integrate external services, we carefully select third-party providers who ensure the implementation of appropriate technical and organizational measures to protect your personal data. However, we cannot guarantee the security of any information transmitted to such third-party providers. We are not liable for any accidental loss or unauthorized access to your personal data due to the actions of third-party providers.

We do not rent or sell your personal data to third parties, but we may share information from tools like cookies, log files, device identifiers, and location data with third-party organizations that provide automatic data processing technologies for the App. We do not have control over these third parties' tracking technologies or their usage.

We may also share certain information, such as cookie data, with third-party advertising partners. This information enables third-party ad networks to deliver targeted ads that they believe will be of most interest to you.

In order to provide us with the necessary infrastructure for the delivery and improvement of our services, we may engage the following third-party service providers:

If you want to know more about the privacy options and services of our App, including how to opt-out, please refer to the respective websites and privacy policies.

Our App may include links to third-party websites or services, or you may access our App from a third-party site. Please note that we are not responsible for the privacy practices of these third-party sites or services, including the information or content contained within them. You are solely responsible for any risk arising from your use of these third-party websites or resources.

Please note that certain third-party providers may engage sub-processors. This implies that your personal data collected by third-party providers can be shared with affiliates as well as other persons engaged thereby. If you want to learn more about the cases of sharing your personal data with sub-processors as well as the scope of your personal data shared therewith please refer to the respective websites and privacy policies of the third-party providers.

We may disclose your personal information in situations where it is necessary for legitimate reasons, such as public interest or in other unforeseen circumstances as required by law. We may also disclose your personal information in good faith to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a government request.

Additionally, if we are involved in a merger, acquisition, or sale of all or a portion of our assets, we will notify you via prominent notice in our App of any change in ownership or usage of your personal information, as well as any options you may have regarding your personal information.

VI. INTERNATIONAL DATA TRANSFERS

We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the information processed automatically across borders and from your jurisdiction to other countries or jurisdictions around the world.

Please be aware that this means we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction. As a result, your personal information may be transferred to a third country, a territory, or one or more specified sectors within that third country, or to an international organization where data protection and confidentiality regulations may not provide the same level of protection for personal data as your jurisdiction does.

By using the App, you agree that we may transfer your personal data to any third country, a territory, or one or more specified sectors within that third country, or to an international organization.

For data storage purposes, we use the services of hosting providers. We take your privacy seriously and, where possible, encrypt your personal data before sending it to the hosting providers for storage. Please note that we only work with hosting providers that have passed our security and reliability checks.

VII. EXERCISING YOUR RIGHTS

Applicable data protection laws give you certain rights regarding your personal information. You have the following options in relation to your personal information that was collected:

• Data Access and Portability. You can request copies of your personal information.
• Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask to correct, change, update or rectify your data.
• Data Retention and Deletion. The user data is generally retained for as long as your user profile is in existence or as it is needed to provide the relevant services. However, specific retention times can vary based on context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.
• Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.
• Exercising the right to know about data sharing. You have the right to know whether your data is shared with third parties. Detailed information on this issue is contained in section IV of the present Privacy policy, however, if you have further questions in this regard, you can contact us at any time.
• Lodge a complaint. You can lodge a complaint with a supervisory authority if you consider that the processing of personal data relating to you infringes the GDPR

You can exercise any of the rights described above by contacting us through our contact form. However, please note that we can only ensure the aforementioned rights with respect to the information that we physically access and store.

If your personal information is being processed automatically, you may have the right to object to such processing in certain circumstances. If your personal information is being processed for direct marketing purposes, you may ask us to stop processing your data for these purposes. To exercise this right, please contact the third-party services listed in Section IV of this Privacy Policy to learn how to object to the processing of your data. Many of them provide clear instructions on their privacy pages, functional API, or other options.

VIII. HOW TO OPT OUT

Location Data Processing

Settings > Privacy > Location Services. Choose the applicable App and set the “Share My Location” status to “Never”. Please refer to this instruction: https://support.apple.com/en-us/HT203033.

Marketing tracking

Either choose option "Limit Ad Tracking" on your iOS device in Settings > Privacy > Advertising or Choose option “Allow Apps to Request to Track" off your iOS device in Settings > Privacy > Tracking. Please refer to instructions here: https://support.apple.com/en-us/HT202074, https://support.apple.com/en-us/HT212025

After you complete an opt-out you may still receive contextual ads that are based on non-personal information.

IX. SECURITY OF DATA

We take the security of your personal information seriously and have implemented measures to protect it from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We follow industry-standard practices to protect the personal information submitted to us during transmission and while in our possession.

To safeguard your personal information, we implement technical and organizational measures that align with data protection principles. We use encryption algorithms, including hashing where feasible, to secure your personal data.

However, it's important to note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we take appropriate measures to protect your personal data, we cannot guarantee its absolute security. In the event of a breach of security that compromises your personal information, we will notify you promptly as required by applicable law.

If you have any questions about the security of our App, you can contact us through the contact form.

X. CHANGES TO THE PRIVACY POLICY

To stay current with our practices and legal obligations, we make regular updates to this Privacy Policy.

If we make any changes to this Privacy Policy, we will update it and post the revised version on this page and other relevant locations. We may also provide you with additional forms of notice regarding the changes, as appropriate in the circumstances.

XI. HOW YOU CAN CONTACT US ABOUT THIS PRIVACY POLICY

You can reach out to us with any inquiries about this Privacy Policy by using our contact form, or by contacting us at [email protected]

CALIFORNIA CONSUMER PRIVACY ACT OF 2018 (CCPA) PRIVACY NOTICE

California residents are entitled to request, in accordance with the CCPA:

• the categories of personal information that is processed;
• the categories of sources from which personal information is obtained;
• the purpose for processing of user personal data;
• the categories of third parties with whom we may share your personal information;
• the specific pieces of personal information that we might have obtained about a particular user provided that the data provided in the request is reliable enough and allows to identify the user.

Please take the time to read this Privacy Policy carefully. By using the App, you acknowledge that you have read, understood, and agree to these terms.

To navigate through this Privacy Policy, please use the provided links.

ADDITIONAL NOTICE: By using our app, you are also subject to the privacy policies and terms of use of the following services: WhatsApp Web (web.whatsapp.com) and Telegram Web (web.telegram.org). When you use our application, you are bound by the privacy policies and terms of use of these applications. Our company does not accept any liability in connection with these services. We provide browser service.

PERSONAL DATA. Learn about the categories, sources, processing methods, and purposes of personal data in Section III >> Note that under the CCPA, personal information excludes de-identified or aggregated consumer information.

SHARING OF DATA. Learn about the methods of sharing your information in Section V >> Please be aware that all third-party processors of user data are service providers who use such information in accordance with a contractual agreement and for a business purpose. To prevent the sharing of device identifiers and geolocation data with service providers, please refer to your device settings for instructions on opting out, as described above in Section VIII >>

SALE OF DATA. We do not engage in the sale of any of your personal data to third parties.

CHOICES TO OPT-OUT. If you would like us to stop processing your personal data, please reach out to us using the contact form. Please note that in many cases, the App cannot function without functional data. In such cases, we may suggest removing the App from your device.

CONSUMER INQUIRY. If you wish to request access, portability, or deletion of your personal information, please get in touch with us using the provided contact form.

When submitting a request, please take note of the following: (a) include the wording "Your rights to maintain confidentiality in the state of California" in the text of your appeal if applicable; (b) describe your request with enough detail for us to understand and respond to it properly; (c) provide sufficient information to allow us to reasonably verify your identity (your name, address, city, state, zip code, and email address). We may use this information to ask you security questions to verify your identity. If you are making a request through an authorized agent, they must provide written authorization or a power of attorney signed by you to confirm their authority to act on your behalf.

In order to fulfill your request for personal information or deletion, we must be able to verify your identity and confirm that the personal information pertains to you. If we cannot verify your identity or the authenticity of the request, we may not be able to fulfill your request or respond to your request. To verify your identity, we may require additional information or documentation. We may also perform identity checks, including through third-party verification services. These measures are in place to protect the security and privacy of your personal information and prevent unauthorized disclosure or modification.

We will handle any personal information provided in a verifiable consumer request with care and ensure that it is only used for the purpose of verifying the requestor's identity or authority to make the request. We will maintain this information for a reasonable period required for the above-stated purpose and dispose of it after the purpose has been accomplished.

We aim to respond to your verifiable consumer request within 45 days of receiving it. If we need more time to respond, we will notify you in writing of the reason and the extension period. It is important to note that we are only obligated to fulfill two requests per customer per year.