Lueurly · Legal Center

Last updated 2026-06-24

Lueurly · Legal Center

Privacy Policy

1. Who We Are

Lueurly is a brand name used by TZU-YU CHIU, an individual developer based in Taiwan (not a registered trademark or company). TZU-YU CHIU (operating as Lueurly) is the operator/the party you contract with.

Contact: [email protected]

Lueurly's backend (API, media, notification, authentication, and related server endpoints) is operated in server environments managed for Lueurly and provided through Lueurly-related service infrastructure, including the lueurly.com domain. Related systems may be deployed in third-party data centers, cloud service providers, or network infrastructure environments.

Lueurly is not directed to, offered to, marketed to, or intended for residents of the European Union, European Economic Area, United Kingdom, Switzerland, or South Korea. We intend to limit availability in excluded regions through App Store Connect geo-restrictions and operational controls where configured and reasonably available. The Service is therefore not intended for residents of those excluded regions; if any mandatory provision of the GDPR, UK GDPR, Digital Services Act, or Korean Location Information Act nonetheless applies, Lueurly will honor the non-waivable rights it grants. Nothing in this Policy excludes any rights that cannot be excluded under applicable law.

2. Data We Collect

The categories of data we collect and process are described below. We do not intend to collect materially different categories of personal data without updating this Policy where required by applicable law or App Store requirements.

CategoryDataWhen collectedPurpose
Account identifiersEmail address, display name, avatar, locale, timezoneRegistration, login, profile useAccount creation, login, localization, account display
Authentication dataPassword stored only as an Argon2id hash, Google identifier, Apple `sub` identifierRegistration, login, SSOAuthentication and account security
Age data`birth_year`Registration or first SSO use18+ eligibility check
Device and technical dataDevice fingerprint made from IDFV and bundle identifier using SHA-256, IP address, user agent, app versionAuthentication, token refresh, security eventsAccount security, new-device detection, audit records, abuse prevention
Push tokensFirebase Cloud Messaging token, Apple APNs tokenApp launch or token refreshPush notifications
Location for Keepsake (pact) signing audit`gps_lat`, `gps_lng`Only when you sign a Keepsake (pact) and the Premium audit-location option is enabledKeepsake (pact) signing audit metadata
IP and user agent for Keepsake (pact) signing auditPublic IP and user agent captured from request headersKeepsake (pact) signing and related security or audit eventsKeepsake (pact) signing audit metadata, abuse prevention, security, and legal compliance
User-generated contentText, voice files, photos, wax seal choices, replies, chat threads, pact content, electronic signatures, and other content created, uploaded, transmitted, or stored by usersWhen you create, upload, send, receive, reply to, store, or sign contentCore messaging and pact features
Message feature flagsFading Light (burn-after-read) duration, Trusted device binding (device-bound) status, Light Up Together (Sync Open) status, Scheduled send (scheduled delivery) time, Anonymous message statusMessage compositionDelivering selected message features
Read receiptsRecipient email, display name, `read_at`When a recipient opens a messageShowing sender read status
Contacts matching dataSHA-256 hashes of normalized email addresses only; we do not store plaintext contact email, phone number, or name for contact syncOnly after your express consentFinding registered friends, suggesting friends, detecting mutual matches, operating automatic-add rules, preventing abuse, and maintaining contact-matching integrity
Friends and blocksFriend email or alias, block list entriesWhen you add, invite, or block usersSocial graph, invitations, abuse prevention
Subscription dataProduct ID, original transaction ID, purchase token, Apple receipt/JWSPurchase and renewalSubscription validation and Premium entitlement
Security recordsLogin attempts, audit logsAutomatically during security-relevant activityAbuse prevention, account protection, operational audit
Content moderation dataReports, report reasons, report notes, screenshot-detection eventsUser reports or client-side eventsUGC safety, objectionable-content review, screenshot notice
PreferencesPush and email settings, quiet hours, anonymous-message preference, biometric-lock setting, marketing opt-inSettings changesPersonalization and consent management

You are responsible for ensuring that your User-Submitted Content is lawful, that you have all rights and permissions necessary to submit it, and that it does not infringe, misappropriate, or otherwise violate any third-party rights. Lueurly does not proactively review all User-Submitted Content and does not assume responsibility for the legality, truthfulness, completeness, or accuracy of User-Submitted Content except to the extent applicable law does not allow such responsibility to be disclaimed.

3. Device Permissions

Lueurly may request optional device permissions for app features:

PermissionUse
MicrophoneRecording voice messages
Speech recognitionVoice-to-text, preferably on device where available
Photo libraryAttaching photos
Location while in useOptional pact-signing audit location (Premium)
Face IDOptional app unlock
ContactsFriend discovery through hashed email matching

If you deny a permission, the related feature may not work, but other app features remain available where technically possible.

4. Why We Process Data

We process data to provide the service, authenticate accounts, deliver messages, operate Premium features, process subscriptions through Apple, secure accounts, prevent abuse, respond to reports, comply with legal obligations, and honor your settings. Where a feature depends on your action or consent, such as contacts matching or optional pact-signing audit location, you may choose not to use that feature or withdraw the relevant permission.

This section describes our operational reasons for processing. It is not intended as a GDPR legal-basis notice; the Service is not directed to, offered to, or marketed to users in the EU, EEA, UK, or Switzerland, but where any mandatory provision of applicable law nonetheless applies, Lueurly will honor the non-waivable rights it grants.

5. How We Use Data

We use account, authentication, and device data to create accounts, log you in, detect new devices, and protect accounts.

We access, process, and use relevant data only to the extent reasonably necessary to provide the Service, maintain system security, prevent abuse, respond to reports, comply with legal obligations, or carry out your requests and selected feature settings.

We use message content and feature flags to deliver messages, schedule delivery, manage Sync Open, apply device-bound restrictions, and support burn-after-read. Except as required by law, authorized by you, or otherwise described in this Policy, we do not proactively read the contents of private user messages.

We use GPS coordinates in only one context: the optional Premium pact-signing audit, and only when you have enabled that option and grant permission at signing time. We do not use GPS or location for Light Up Together (Sync Open). Light Up Together relies only on a shared time window and a count of participants who choose to "light up"; it does not collect, transmit, share, or evaluate any location data. We do not continuously track location.

We use pact audit IP, user agent, GPS where enabled and available, device, and timestamp metadata only as system records, audit metadata, security records, and legal-compliance records. Pact audit settings may control selected enhanced audit fields or client-side GPS capture, but they do not prevent Lueurly from creating ordinary technical, security, anti-abuse, legal-compliance, or transaction records. Lueurly does not represent or warrant that such records have any particular legal effect, evidentiary admissibility, or enforceability; actual legal effect depends on applicable law and the determination of the competent authority or court.

We use contact hashes only for contact matching and related integrity purposes. Contact matching is optional and requires your action or consent. If enabled, the app reads email addresses from your device contacts, normalizes them locally, creates SHA-256 hashes locally, and uploads only those hashes to the server for matching. We do not upload or store plaintext contact names, phone numbers, postal addresses, notes, or plaintext contact email addresses for contact sync. Email hashes reduce exposure but may still be personal data because they can correspond to identifiable email addresses.

Lueurly may use contact hashes to find registered users, suggest friends, detect mutual matches, automatically add friends only where mutual-match rules or service configuration allow it, prevent abuse, measure eligibility, operate the feature, and maintain the integrity of friend-discovery systems. Lueurly may determine or change matching criteria, ranking, suggestion logic, automatic-add logic, frequency, eligibility, retention, and availability of contact matching, subject to applicable law. If you withdraw consent or delete synced contact hashes, future matching may stop, but existing friend relationships, invitations, blocks, abuse records, safety records, or other records separately maintained under the Service may remain until removed under the applicable feature or retention rule.

Firebase is used only for push delivery through FCM. Firebase Analytics is disabled, advertising is disabled, and Lueurly does not include third-party tracking SDKs such as Crashlytics, Sentry, or Mixpanel.

We do not sell personal data. We do not share personal data for cross-app tracking. We do not use your data for third-party advertising.

6. Processors and Third Parties

We share data with service providers only as needed to operate Lueurly.

ProviderData involvedPurposeRegion
AppleApp Store transactions, APNs token, Sign in with Apple identifierPayments, push notifications, loginGlobal
GoogleFCM token, Google Sign-In identifierPush notifications, loginGlobal
Hetzner Online GmbHBackend service dataHosting and infrastructure servicesOutside the United States
Resend, through an internal relayRecipient email address and email contentsTransactional and notification email deliveryUnited States
CloudflareDNS, TLS, routing, email-routing, and related technical metadataDNS, TLS, security, routing, and email-routing infrastructureGlobal

These service providers may apply their own terms and privacy practices. We are not responsible for third-party services outside our control, but we select and use service providers as reasonably necessary to operate, secure, and support the Service.

Hetzner Online GmbH provides hosting and infrastructure services. Hetzner acts only as a service provider and data processor for infrastructure purposes; using such an infrastructure provider does not make Lueurly an entity established in the European Union or, by itself, automatically subject Lueurly to the GDPR.

Lueurly's backend (API, media, notification, authentication, and related server endpoints) is managed and operated by us and provided through the lueurly.com domain. Related systems may be deployed in third-party data centers, cloud service providers, or network infrastructure environments operated by reputable providers.

Apple processes App Store payments. Lueurly does not receive or store your payment card number.

6A. Legal Requests and Law-Enforcement Disclosures

We may disclose relevant data when reasonably necessary to:

  • comply with law, court orders, subpoenas, warrants, government requests, or other valid legal process;
  • protect the rights, safety, and property of Lueurly, users, or third parties;
  • investigate fraud, abuse, harassment, threats, intellectual-property violations, child-safety incidents, or other unlawful conduct;
  • enforce the Terms of Service, Community Guidelines, or other applicable policies; or
  • respond to disputes, claims, or security incidents.

To the extent permitted by law, we seek to disclose only the information reasonably necessary for the applicable purpose.

Where we become aware of apparent child sexual abuse material or sexual exploitation of minors, we may preserve relevant information and report it to the National Center for Missing & Exploited Children (NCMEC) and to law enforcement as required or permitted by law.

6B. Business Transfers

If Lueurly's operation, assets, or service responsibilities are transferred to a successor, purchaser, assignee, newly formed legal entity, or other operator that assumes or continues the Service, we may transfer relevant data as reasonably necessary for that transition, provided that the recipient is required to handle the data under this Policy or privacy safeguards that are materially comparable.

7. Storage Location and International Transfers

We use reputable third-party infrastructure providers to host and process information on our behalf. Your information may be stored and processed on servers located outside the United States and outside your country of residence. Lueurly is operated from Taiwan.

By using the Service, you understand that your information may be transferred to and processed in countries other than your own, including the United States for email delivery through Resend and global network-routing services through Cloudflare. Where information is transferred across borders, we take steps designed to protect it in a manner consistent with this Policy and applicable law.

This disclosure is provided for transparency. Using third-party hosting or infrastructure providers does not by itself establish Lueurly in the EU or subject the Service to the GDPR; where any mandatory provision of applicable law nonetheless applies, Lueurly will honor the non-waivable rights it grants.

8. Retention

We retain data according to the verified retention schedule below:

DataRetention
Fading Light (burn-after-read) content, including text, photos, and voice filesCleared from active server storage no later than 1 hour after the applicable read and expiry condition is satisfied; for multi-recipient messages, content may remain until all relevant recipients satisfy the system's purge condition
Contact hashesDeleted after 90 days without update
Keepsake (pact) signing audit location (`gps_lat`, `gps_lng`), only when the Premium audit-location option is enabledCleared after 90 days
Login attempts30 days
Audit logs, including IP, user agent, and device fingerprint180 days
Web access logs, including IP14 days
Application logs30 days
Database backups30-day rolling backups
Account data and remaining contentKept while the account exists; deleted or anonymized within a reasonable period after account deletion, subject to the limited exceptions described in this Policy

Burn-after-read is best-effort. Lueurly cannot prevent recipients from taking screenshots, screen recordings, photos of the screen, external recordings, notification previews, device backups, or other external copies before deletion. Cleared burn-after-read content is not retained long-term, and backups roll over within 30 days. Limited metadata, logs, legal holds, safety records, abuse reports, payment records, dispute records, or legally required records may be retained for the periods described in this Policy and the Data Retention Policy.

After account deletion, we will delete or anonymize relevant data within a reasonable period. To comply with legal obligations, prevent abuse, resolve disputes, enforce the Terms of Service, protect rights, process payments or refunds, or maintain system security, we may retain limited data for as long as reasonably necessary to complete the applicable purpose.

9. Your Choices and Rights

You may access, correct, or update account information in the app where available.

You may delete your account through the account-deletion feature provided in the app. Account deletion starts the process for deleting account data and related content, subject to the retention periods and limited exceptions described in this Policy.

Account deletion may be irreversible. Certain records generated through interactions with other users, transaction records, audit logs, report records, safety records, or data that must be retained by law or for legitimate security, anti-abuse, dispute-resolution, or policy-enforcement purposes may continue to be retained in accordance with this Policy.

Account deletion may cancel, disable, delete, or anonymize pending scheduled sends, drafts, Premium-dependent settings, contact-sync data, friend data, device sessions, push tokens, and other account-tied service records. Deleting your Lueurly account does not necessarily cancel an active Apple subscription; Apple subscription management remains handled by Apple.

You may request deletion by email if you cannot access the app: [email protected].

Where available, you may use export features provided in the app to download relevant message, pact, and related account data. Lueurly does not currently provide a single complete machine-readable account export feature.

You may delete contact-sync data through the app's contact-sync controls, withdraw optional device permissions in iOS Settings, block users, report content, log out devices, and change notification, email, anonymous-message, biometric-lock, and marketing preferences.

10. US State Privacy Notice

Lueurly does not sell personal information and does not share personal information for cross-context behavioral advertising. Lueurly does not use personal data for cross-app tracking.

Some US state privacy laws apply only to businesses that meet revenue, user-volume, or data-sale thresholds. Lueurly may not meet those thresholds. Even where a law does not apply, you may contact us at [email protected] to request access, correction, deletion, or information about our data practices.

If Lueurly's operations grow in a way that makes specific state privacy laws applicable, we will update this Policy and the related user-rights disclosures as required by applicable law.

11. Security

Lueurly uses reasonable administrative, technical, and organizational safeguards, including HTTPS/WSS encryption in transit, Argon2id password hashing, Keychain session storage, and device/security audit controls.

Although we use reasonable security measures, no electronic storage, network transmission, or information system can be guaranteed to be completely secure. You are responsible for keeping your account credentials and trusted devices secure.

To the maximum extent permitted by law, Lueurly is not responsible for damages caused by third-party attacks, user negligence, compromised user devices, force majeure events, infrastructure failures outside our reasonable control, or other circumstances beyond Lueurly's reasonable control.

12. Children and Adults Only

Lueurly is for adults only. You must be at least 18 years old to use the service. Lueurly is not directed to children or minors. We use `birth_year` to help enforce the 18+ requirement. Lueurly does not knowingly collect personal information from children under 13. If we learn that an underage account exists, we may suspend, disable, terminate, delete, or anonymize the account and related data as appropriate and as permitted or required by law.

13. Changes to This Policy

We may update this Privacy Policy as the service, law, or operational practices change. For material changes, we will provide reasonable notice through the app, website, email, or another appropriate method before the change takes effect where practical.

14. Contact

For privacy requests, account deletion help, security questions, or complaints, contact:

[email protected]

The official version and controlling language of these documents are governed by Section 27 of the Lueurly Common Terms of Use.

Last updated: 2026-06-28 Nature of this version: These Common Terms of Use are the master agreement to which you individually agree within the App.

> These Common Terms of Use (the "Terms") are the master agreement between you and the operator of the Service in respect of the Lueurly service. The Privacy Policy, Acceptable Use Guidelines, Data Retention Policy, Account Deletion Notice, Children and 18+ Statement, Subscription and Refund Disclosure, and DMCA Copyright Policy (the "Individual Policies") are incorporated into and form part of these Terms.

1. Definitions

"The operator of the Service," "we," or "us" means TZU-YU CHIU, an individual developer based in Taiwan, operating as Lueurly (not a registered trademark or company), being the operator of and the contracting counterparty for the Lueurly service. Contact: [email protected].

"Lueurly," "the Service," or "the App" means the Lueurly iOS App, the backend services, the website legal center, the messaging functions, the Keepsake archive functions, the subscription functions, and related services.

"Content" means the text, voice, photos, Keepsake archives, signatures, wax seals, replies, chat threads, metadata, and other materials provided through the Service. "User Submitted Content" means content that you create, upload, send, receive, sign, report, or otherwise submit through the Service.

"Service Fee" means the charge for paid features. "Subscription" means the auto-renewing Premium subscription offered through Apple StoreKit. "Individual Service Terms" means terms separately established for a specific feature and presented to you.

"Product feature names": certain features are referred to by both a product name and a functional description, both of which refer to the same feature: "Fading Light" means burn-after-read (a best-effort feature that, after reading, clears the message content from the server's active storage on a timer); "Light Up Together" means Sync Open (a shared time-window open feature that does not use location); "Keepsake" means the pact (a personal commitment and record feature, including optional witness friends, that can be exported as a PDF); "Trusted device binding" means device-bound; "Scheduled send" means scheduled delivery; "Anonymous message" means anonymous.

2. Use of and Consent to the Service (18+)

To use the Service, whether or not a service fee applies and whether or not account registration is required, you must agree to these Terms. When you tap to agree within the App, create an account, access the Service, purchase a subscription, send messages, sign a Keepsake, or otherwise use the Service, you accept these Terms.

You must be at least 18 years of age. Lueurly is for adults only, is rated for an adult audience, and is not designed, marketed, or offered for children or minors. Lueurly uses a neutral age screen and requires you to declare that you are at least 18 years old; by using the Service you represent and warrant that this declaration is true. The neutral age screen is only a screening mechanism and is not a guarantee of identity or age verification. If we learn of or have actual knowledge that an account belongs to a person under 18 (or that we have collected personal information of a child under 13), we may, to the extent permitted or required by applicable law and as appropriate, suspend, disable, terminate, delete, or anonymize that account and the related data.

3. Account Registration Information

When registering an account, you are obligated to provide true, accurate, and non-misleading information and to proactively correct it to keep it current. The account is personal to you and, except as permitted by the Service, may not be assigned, sold, leased, lent, or otherwise granted to a third party. If your account is deleted or terminated, your right to use the Service ends.

Without the prior written consent of the operator of the Service, you may not assign, transfer, or delegate your rights or obligations under these Terms. The operator of the Service may assign or transfer these Terms in connection with a service reorganization, legal succession, asset transfer, or change in operations, without diminishing your rights under mandatory law.

4. Provision of the Subscription Service

Lueurly Premium is offered through Apple StoreKit as a monthly auto-renewing subscription. The actual price, taxes, and currency are as displayed in the App Store at the time of purchase. Unless you cancel at least 24 hours before the end of the current period, the subscription will automatically renew. Apple processes payment and refunds; the operator of the Service does not receive your card number and does not separately process App Store refunds.

Premium features are provided only during the period in which both Apple and the Lueurly entitlement system show a valid entitlement. Subscription expiration, charge failure, refund, revocation, end of a grace period, or account deletion or termination may cause Premium features to be disabled immediately. Features that rely on Premium (including Scheduled send, Fading Light, Light Up Together, Trusted device binding, Anonymous message, and the creation or export and audit settings of Keepsake) may re-verify the entitlement at operationally relevant times, such as creation, use, renewal, processing, or scheduled delivery; if the entitlement has lapsed at that point, then except where prohibited by law or App Store rules, the operator of the Service may cancel, downgrade, disable, delete, or refuse to deliver the relevant features, messages, settings, or records.

5. No Emergency Reporting Function

Lueurly is not an emergency, rescue, medical, law enforcement, or alert service. Do not use Lueurly to request emergency assistance or to send time-sensitive safety communications; contact your local emergency services directly.

6. Content and Minimum Necessary License

You retain ownership of your User Submitted Content, without affecting the rights of others. You grant the operator of the Service a limited, non-exclusive, worldwide license, solely to the extent reasonably necessary, to host, store, transmit, display, process, and technically reproduce your User Submitted Content, in order to operate, protect, review, support, and improve the Service and to comply with the law. You represent that you have the rights necessary to submit it and that the content does not violate these Terms, the Acceptable Use Guidelines, or applicable law.

7. Handling of User Data and Content

Due to limitations of the technical architecture and security controls, the operator of the Service does not, under ordinary circumstances, proactively review User Submitted Content; however, where reasonably necessary to handle reports, abuse investigations, legal compliance, security incidents, enforcement of these Terms, or operation or protection of the Service, it may process the relevant data in accordance with these Terms and the Privacy Policy.

8. Review and Deletion of Messages

Messages are generally available only to the sender, the recipient, and the system processes necessary to deliver the Service. Certain metadata (for example, delivery, read, device, Light Up Together activation, Keepsake audit, report, or screenshot-detection records) may be processed for the relevant features.

9. Account and Password Responsibility

You are responsible for maintaining the confidentiality of your account credentials and trusted devices. Except as caused by the willful misconduct or negligence of the operator of the Service, you are responsible for activity carried out through your account. If you suspect unauthorized access, you should notify us as soon as possible at [email protected].

10. Provision, Suspension, and Termination of the Service

You are responsible for your device, operating system, network connection, telecommunications charges, and a compatible software environment. The operator of the Service may suspend, restrict, or interrupt all or part of the Service where reasonably necessary for maintenance, security, abuse prevention, legal compliance, infrastructure failure, force majeure, or other operational reasons. For planned material interruptions, reasonable notice will be provided to the extent practicable.

If you violate these Terms or the Acceptable Use Guidelines, create legal or security risk, abuse Anonymous message, infringe rights, circumvent review, use a minor's account, or harm the Service or other users, the operator of the Service may suspend, restrict, or terminate your account or access. For ordinary violations, an attempt will be made to notify you to the extent practicable; for serious abuse, fraud, security threats, child sexual abuse material, imminent harm, legal risk, or repeated violations, action may be taken without prior notice. You may delete your account within the App via Settings -> Delete Account; if you cannot use the App, you may contact [email protected]. Deletion is handled in accordance with the Account Deletion Notice and the Data Retention Policy.

11. Service Provided As Is, No Warranty, and Nature of Features

The Service is provided on an "as is" and "as available" basis. To the maximum extent permitted by law, the operator of the Service makes no warranty of merchantability, fitness for a particular purpose, title, non-infringement, uninterrupted operation, error-free operation, availability, accuracy, or data retention. Consumer rights that may not be waived under the law are unaffected.

Feature names such as "Fading Light" (burn-after-read), "Light Up Together" (Sync Open), "Trusted device binding" (device-bound), and "Anonymous message" are merely descriptive shorthand for the convenience of the features and are not a promise of confidentiality, security, encryption, irreversibility, deletion, anonymity, or any particular outcome. Fading Light is a convenience feature and is not a guarantee of information security, encryption, or confidentiality, and it cannot prevent a recipient or others from retaining, screenshotting, recording, or copying content. Do not use the Service to send information you need to keep confidential. Burn-after-read content is cleared from the server's active storage within at most 1 hour after the applicable read and expiry conditions are met; for a multi-recipient message, content may be retained until all relevant recipients meet the system clearance conditions. The operator of the Service does not promise immediate, irreversible, forensic-level, or recipient-device-side deletion.

12. Prohibited Conduct

The operator of the Service has a zero-tolerance policy toward objectionable content and abusive conduct, including any sexual exploitation, online enticement, or child sex trafficking of minors. You may not use Lueurly to: violate the law or the rights of others; harass, threaten, stalk, extort, impersonate, dox, or abuse any person; send hateful, extremist, sexually exploitative, non-consensual intimate, violent, gory, or other offensive content; create, request, possess, distribute, or promote child sexual abuse material; spam, phish, defraud, manipulate, or deceive; upload malware, exploit vulnerabilities, bypass security controls, scrape, or overload the Service; reverse engineer the Service (except where applicable law confers a non-waivable right); use Anonymous message to evade responsibility; share accounts, resell access, or use the Service for unauthorized commercial messaging; or interfere with the reporting, review, subscription, payment, or security systems.

Anonymous message may hide the sender from the recipient, but anonymity does not mean immunity. The operator of the Service will retain identifying information for safety, abuse-prevention review, legal compliance, and appropriate law enforcement requests.

13. Contact Matching and Friend Discovery

Contact matching is an optional feature that you actively enable. If enabled, the operator of the Service may read the email addresses in your device's contacts, normalize them locally and generate SHA-256 hashes, and upload only those hashes to the server for matching; contact names, phone numbers, addresses, notes, or plaintext email addresses are not uploaded. You must ensure that you have lawful authorization. You may withdraw consent or delete synced hashes at any time, except that existing friend relationships, invitations, blocks, and abuse or security records may be retained in accordance with the applicable features or retention rules.

14. Intellectual Property and Restrictions on Use of the Service

The operator of the Service and its licensors reserve all rights in the App, software, interfaces, designs, service names, trademarks, documentation, backend systems, and other non-user materials. The operator of the Service grants you a limited, personal, non-transferable, non-sublicensable, and revocable permission to use the Service for your personal, lawful purposes. Except as expressly permitted by these Terms or mandatory law, you may not copy, modify, distribute, sell, lease, sublicense, or host the Service or create derivative works. Copyright complaints are handled in accordance with the DMCA Copyright Policy. Before the DMCA Copyright Policy takes effect (that is, before the designated agent is registered and the policy is published), copyright complaints are handled under the general notice procedure via [email protected].

15. Light Up Together Safety and Offline Interaction

Lueurly is a digital messaging service. Light Up Together (Sync Open) is a time-window feature: when participants each choose to "light up" within a shared time window, the message opens. This feature does not use, collect, or require your location, and does not require you to be in any particular place or near any other person. Some users may choose to use Light Up Together when they happen to be physically together, but that is entirely their own voluntary choice, which the operator of the Service neither directs nor requires as a precondition. Because such features may involve interacting with others in the real world, you should confirm the safety of your location and surroundings before acting. If you choose to meet or interact with other users offline, you do so entirely at your own risk and assume that risk. The operator of the Service does not arrange, facilitate, supervise, or guarantee any in-person meeting and is not responsible for offline conduct, meetings, or their consequences. In an emergency, contact your local law enforcement or emergency services immediately. This clause does not limit any liability that may not be excluded under the law.

16. Keepsake and Electronic Signing

The signing records and audit metadata provided by the operator of the Service (which may include time, device information, IP address, user agent, and, when enabled and available, GPS) serve only as supporting evidence of an expression of intent. The operator of the Service does not provide legal advice; the operator of the Service is not a law firm, notary, witnessing service, or contract drafting service, and does not verify the identity of signatories. The Keepsake feature is a personal record-keeping and audit-metadata tool and is not a qualified, certified, or witnessed electronic signature service, and it does not guarantee compliance with eIDAS QES, ESIGN, UETA, or any electronic signature law. Whether a pact has legal effect, evidentiary capacity, or enforceability depends on applicable law, the facts, the true intent of the parties, and the determination of a competent authority or court. For any agreement that you intend to be legally binding, consult a qualified attorney and use an appropriate method of signing; never rely on a Keepsake as a legal contract or proof of identity.

17. User Indemnification of the Operator of the Service

To the extent permitted by law, if, as a result of your willful or negligent breach of these Terms, your User Submitted Content, your misuse of the Service, your violation of the law, or your infringement of the rights of others, a third party brings a claim against the operator of the Service or the operator of the Service incurs loss, damage, liability, cost, or reasonable expense, you agree to indemnify and hold the operator of the Service harmless; except as to the portion caused by the operator of the Service's own unlawful conduct, willful misconduct, or gross negligence. This indemnification obligation does not apply to the extent prohibited by mandatory consumer protection law.

18. Disclaimer

18.1. Except as caused by the willful misconduct or gross negligence of the operator of the Service, the operator of the Service bears no liability arising under any circumstances.

18.2. Notwithstanding the foregoing, if the contract between you and the operator of the Service concerning the use of the Service under these Terms constitutes a consumer contract as defined by the Consumer Protection Act of the Republic of China (Taiwan), then, except as caused by the willful misconduct or gross negligence of the operator of the Service, the operator of the Service shall be liable to compensate only for loss or damage within the ordinary scope, with the amount of compensation capped at the Service Fee for the paid service (equivalent to one month's fee in the case of a subscription service), and excluding lost profits and other damages arising from special circumstances.

18.3. If loss is caused to you by the gross negligence of the operator of the Service, the operator of the Service does not compensate for lost profits or other damages arising from special circumstances, and is liable only for loss or damage within the ordinary scope, with the amount of compensation capped at the Service Fee for the paid service (equivalent to one month's fee in the case of a subscription service); provided, however, that if the contract between you and the operator of the Service concerning the use of the Service under these Terms constitutes a consumer contract as defined by the Consumer Protection Act of the Republic of China (Taiwan), the foregoing arrangement does not apply.

18.4. These Terms do not exclude or limit liability for personal injury, fraud, willful misconduct or gross negligence, or any liability that may not be excluded or limited under the law.

19. Dispute Resolution, Binding Arbitration, and Class Action Waiver

Please read this clause carefully. This clause affects your legal rights. Except as provided below and as otherwise required by mandatory law, for **users residing in the United States**, most disputes must be resolved by individual arbitration with a waiver of class actions.

19.1. Informal negotiation first: Before commencing any arbitration or proceeding, you and the operator of the Service agree to first attempt to resolve the dispute informally for at least sixty (60) days (by writing to [email protected]).

19.2. Individual arbitration (U.S. users): If you reside in the United States, any dispute arising out of these Terms or the Service, except for the exceptions in Section 19.5 and where you have validly opted out under Section 19.4, shall be resolved by binding individual arbitration conducted by the American Arbitration Association (AAA) under its Consumer Arbitration Rules, governed by the U.S. Federal Arbitration Act (FAA, 9 U.S.C. §§1 et seq.).

19.3. Class action and jury waiver (U.S. users): Arbitration is conducted on an individual basis only; both you and the operator of the Service waive the right to bring or participate as a class, collective, representative, or private attorney general, and waive a jury trial. If the class action waiver is found unenforceable as to a particular claim, that claim shall be severed to court while the rest proceeds in arbitration.

19.4. Thirty-day right to opt out: Within 30 days after first accepting these Terms, you may opt out of Sections 19.2–19.3 by email ([email protected]) stating your account email and your intent to opt out of arbitration. Those who opt out are subject to Section 26.

19.5. Exceptions: Claims within the scope of small claims court, seeking an injunction or equitable relief for intellectual property rights or unauthorized use, and the operator of the Service's collection of subscription fees, are not subject to arbitration.

20. Apple App Store Additional Terms

When you obtain the App through the Apple App Store, the following additional terms apply and, in the event of any inconsistency with the other terms, prevail: These Terms are solely between you and the operator of the Service, and not with Apple Inc. ("Apple"); Apple is not responsible for the App or its content and has no maintenance or support obligation. To the maximum extent permitted by law, Apple provides no warranty; if the App fails to conform to a warranty, you may notify Apple, and Apple may refund the purchase price (if any). Apple is not responsible for addressing any claim by you or a third party relating to the App (including product liability, non-compliance with law, and consumer protection claims). If a third party alleges that the App infringes its intellectual property rights, then to the extent required by law, the operator of the Service (and not Apple) is responsible for addressing it. You represent that you are not located in a country that is subject to a U.S. embargo or designated as supporting terrorism, and that you are not on any U.S. list of prohibited or restricted parties. Apple and its subsidiaries are third-party beneficiaries of these Terms and may enforce these Terms against you in that capacity.

21. Third-Party Services

The operator of the Service relies on third-party services (including infrastructure service providers such as Apple, Google, Firebase Cloud Messaging, Hetzner Online GmbH, Resend, and Cloudflare). Those service providers are subject to their own terms and privacy practices. The operator of the Service is not responsible for third-party services beyond its control, but will select processors in accordance with the Privacy Policy to operate the Service.

22. Notices

The operator of the Service may send notices through the App, email, the website, push notifications, or other reasonable means. Contact and dispute point of contact: [email protected].

23. Privacy

The Privacy Policy explains how the operator of the Service collects, uses, stores, discloses, and retains personal data. Before using the Service, you should read and understand the Privacy Policy. For processing activities that require consent under the law, the operator of the Service will obtain the necessary consent in accordance with applicable law.

24. Priority of Individual Service Terms and Individual Policies

If there is any difference between these Terms and the Individual Service Terms, then, unless otherwise agreed, the Individual Service Terms prevail for that specific feature. These Terms and the Individual Policies (Privacy Policy, Acceptable Use Guidelines, Data Retention Policy, Account Deletion Notice, Children Statement, Subscription Disclosure, DMCA Policy) constitute the entire agreement between you and the operator of the Service. Each Individual Policy prevails within the scope of its respective subject matter (such as privacy, retention periods, community standards, refunds, copyright handling); only where the general provisions of these Terms and an Individual Policy conflict and the matter falls outside the aforementioned subject matter do these Terms control, in order to avoid inconsistency.

25. Changes to the Terms

The operator of the Service may update these Terms due to changes in the Service, the law, security needs, subscription, or operational practices. Material changes will be reasonably notified before they take effect through the App, the website, email, or other appropriate means. If applicable law or App Store rules require express consent for a material change, the operator of the Service will request that consent before the updated terms apply to you. If you continue to use the Service after a reasonable notice period, you are deemed, to the extent permitted by law, to have accepted the updated terms.

26. Governing Law and Jurisdiction

The interpretation and application of these Terms are governed by the laws of the Republic of China (Taiwan). For any dispute arising out of or relating to these Terms or the Service, except for the arbitration agreement applicable to U.S. users under Section 19, the Taiwan Taipei District Court shall be the court of first instance; provided, however, that this does not apply where applicable mandatory law confers on a consumer the right to sue or be sued in the courts of the consumer's place of residence. This jurisdiction agreement does not deprive a consumer of the mandatory protections enjoyed under the laws of the consumer's place of residence. The arbitrability of the arbitration agreement for U.S. users is governed by the FAA.

27. Official Version and Language

These Terms have the **Traditional Chinese version as the official version**. The making, validity, and interpretation of these Terms are governed by the Traditional Chinese version. The English version and other language versions are translations provided for convenience only; in the event of any discrepancy among the versions, the Traditional Chinese version prevails. However, the foregoing choice of language does not diminish the non-waivable rights enjoyed by a consumer under the mandatory law of the consumer's place of residence; where mandatory law entitles a consumer to invoke its language version, that version prevails for that consumer to the extent of the conflict. In addition, with respect to the arbitration agreement for users residing in the United States under Section 19, the English version may prevail to the extent necessary for interpretation and enforcement under the U.S. Federal Arbitration Act (FAA), in order to maintain the enforceability of that arbitration agreement.

(This "Official Version and Language" clause is the only clause among all of Lueurly's legal documents that declares an official version; the other documents do not separately declare an official language version. However, a document produced solely in English to comply with a specific foreign law—such as the DMCA Copyright Policy produced in English for U.S. DMCA compliance—has its English text as the applicable version, and the foregoing Traditional-Chinese-official rule does not require such an English-only document to also have a Traditional Chinese version.)

28. Limitations on the Application of These Terms

Lueurly does not target residents of the European Union, the European Economic Area, the United Kingdom, Switzerland, or South Korea, and is not offered or marketed to those regions. The Service is not directed to residents of those excluded regions; if the mandatory law of those regions nonetheless applies, the operator of the Service will comply with the non-waivable rights it confers. These Terms do not exclude any user rights that may not be excluded under the law.

29. Severability

If any provision of these Terms is held invalid, unlawful, or unenforceable in any jurisdiction, that provision will be severed or reduced to the minimum required by law in that jurisdiction, and the remaining provisions will remain in full force and effect. The survival and severability of Section 19 (Arbitration) are governed by that section.

Community Guidelines

1. Scope

These Community Guidelines apply to all content and conduct in Lueurly, including messages, voice, photos, replies, chat threads, Keepsake (pact) content, signatures, reports, profile information, Anonymous messages, Light Up Together (Sync Open) interactions, and any other user-generated content.

Lueurly is for adults only. Users must be at least 18 years old.

2. Prohibited Content and Conduct

You may not create, send, request, upload, promote, or encourage:

  • harassment, bullying, threats, stalking, blackmail, intimidation, or abuse;
  • hate, dehumanization, extremist content, or attacks based on protected or vulnerable characteristics;
  • sexual exploitation, non-consensual intimate content, sexual coercion, or image-based abuse;
  • child sexual abuse material, sexualization of minors, grooming, or any child exploitation;
  • graphic violence, credible threats, self-harm encouragement, or instructions for violent wrongdoing;
  • fraud, scams, phishing, impersonation, deception, spam, or manipulative schemes;
  • doxing, unauthorized sharing of private information, or privacy invasion;
  • malware, credential theft, exploit instructions, automated scraping, or security bypass;
  • unlawful goods, services, transactions, or instructions;
  • copyright infringement or other intellectual-property violations;
  • content designed to evade reports, blocks, moderation, subscriptions, payment systems, or safety controls.

3. Anonymous Messages

Anonymous messages may hide the sender from the recipient, but anonymity is not impunity. Lueurly retains identifying information, including account, device, IP, and audit metadata, to investigate abuse, enforce these Guidelines, comply with law, and respond to valid law-enforcement requests.

Recipients may disable anonymous messages where the app provides that setting and may block users.

4. Reports, Blocking, and Bans

Users can report objectionable content and block abusive users in the app. Reports may include a reason, note, and relevant content or metadata needed for review.

Lueurly aims to review reported objectionable content within 24 hours and will use commercially reasonable efforts to respond promptly, prioritizing reports involving safety threats, child exploitation, non-consensual intimate content, fraud, or severe abuse. Where a report is substantiated, Lueurly may remove violating content and suspend, restrict, or ban the violating account.

For severe abuse, safety threats, child exploitation, fraud, or repeated violations, Lueurly may act without prior notice.

5. CSAM Zero Tolerance

Lueurly has zero tolerance for child sexual abuse material, child sexual exploitation, grooming, or sexualization of minors.

Moderation may depend on user reports and manual review of reported content or metadata. If Lueurly becomes aware of apparent CSAM or child exploitation, Lueurly may preserve relevant information, terminate accounts, report to the National Center for Missing & Exploited Children (NCMEC) under 18 U.S.C. §2258A where applicable, and cooperate with law enforcement.

6. Underage Users

Lueurly is not for minors. If Lueurly learns that a user is under 18, Lueurly may suspend, disable, terminate, delete, or anonymize the account and related data as appropriate and as permitted or required by law.

Do not use Lueurly to contact, groom, solicit, exploit, or endanger minors.

7. Enforcement

Depending on severity and context, Lueurly may warn users, remove content, restrict features, block delivery, disable anonymous messaging, suspend accounts, ban accounts, preserve evidence, or disclose information to law enforcement where legally appropriate.

Attempts to evade enforcement, including creating new accounts after a ban, may lead to further restrictions.

8. Contact

For reports, safety concerns, intellectual-property issues, or appeals, contact:

[email protected]

9. Account Restriction Standards

Based on reports and our review, Lueurly may restrict an account that violates these Guidelines or applicable law, including temporarily suspending the ability to send messages and use in-letter chat, or permanently disabling the account. Typical measures may include a first-violation sending suspension of about 3 days, a repeat-violation suspension of about 7 days, and longer restrictions for severe harassment or threats. Conduct that is unlawful or involves child sexual abuse or exploitation (CSAE), sexual exploitation, or non-consensual intimate imagery may result in permanent account termination, preservation of relevant evidence, and reports to the National Center for Missing & Exploited Children (NCMEC), law enforcement, or other competent authorities where required or permitted by law. During a sending suspension, you can still receive and read messages unless the account is disabled or access is legally or operationally restricted. Lueurly applies these measures at its reasonable discretion; actual periods may vary with the circumstances.

The official version and controlling language of this document are governed by Section 27 of the Lueurly Common Terms of Use.

Subscription and Refund Disclosure

1. Premium Subscription

Lueurly Premium is an auto-renewable monthly subscription for Premium features, including the Premium feature set described in the app and paywall.

Product ID: `com.lumora.premium.monthly`

The current price is shown in the App Store at the time of purchase. The App Store displays the applicable local price, taxes, and currency conversion.

2. Auto-Renewal

Payment is charged to your Apple Account at confirmation of purchase. The subscription renews automatically unless cancelled at least 24 hours before the end of the current billing period.

Your Apple Account may be charged for renewal within 24 hours before the end of the current period, according to Apple's App Store rules.

3. Cancellation

You can manage or cancel the subscription in your Apple Account subscription settings. Deleting the Lueurly app or deleting your Lueurly account does not necessarily cancel your Apple subscription.

Apple subscription management: https://support.apple.com/billing

4. Premium Entitlement and Pending Premium Features

Premium access and Premium-only features are available only while Apple and Lueurly entitlement systems indicate an active, valid Premium entitlement. Turning off auto-renewal may not immediately end Premium access if Apple continues to report an active entitlement through an already paid period. Expiration, failed billing, refund, revocation, grace-period expiration, account deletion, termination, or any other loss or inactivation of entitlement may immediately disable Premium features inside Lueurly.

Premium-dependent scheduled sends and other future-dated Premium actions may be checked again at processing or delivery time. If entitlement is inactive at that time, Lueurly may cancel, withhold, disable, delete, or decline to deliver the related feature, message, configuration, or record, except where prohibited by law or App Store rules.

5. Refunds

Apple handles App Store payment processing and refund requests. Lueurly does not receive your card number and does not separately process App Store refunds.

Apple refund requests: https://reportaproblem.apple.com/

6. Immediate Digital Delivery and Cooling-Off

Premium digital content and features may be delivered immediately after purchase. Any statutory withdrawal, cancellation, or cooling-off rights for digital content are handled to the extent required by applicable law and the App Store purchase flow. Once digital content or services begin, withdrawal rights may be limited where permitted by law.

7. Links

Privacy Policy: https://lueurly.com/legal/privacy

Terms of Service: https://lueurly.com/legal/terms

Contact: [email protected]

The official version and controlling language of this document are governed by Section 27 of the Lueurly Common Terms of Use.

Data Retention Policy

1. Purpose

This policy explains how long Lueurly keeps different categories of Lueurly data. It reflects the verified retention schedule in effect on 2026-06-16.

2. Retention Schedule

DataRetention
Fading Light (burn-after-read) content, including `content_text`, photos, and voice filesCleared from active server storage no later than 1 hour after the applicable read and expiry condition is satisfied; for multi-recipient messages, content may remain until all relevant recipients satisfy the system's purge condition
Contact hashesDeleted after 90 days without update
Keepsake (pact) signing audit location (`gps_lat`, `gps_lng`), only when the Premium audit-location option is enabledCleared after 90 days
Login attempts30 days
Audit logs, including IP, user agent, and device fingerprint180 days
Web access logs, including IP14 days
Application logs30 days
Database backups30-day rolling backups
Account data and remaining contentKept while the account exists; deleted or anonymized within a reasonable period after account deletion, subject to the limited exceptions described in this policy

3. Fading Light (Burn-After-Read)

Burn-after-read content is cleared from active server storage no later than 1 hour after the applicable recipient reads it and the configured countdown expires. For multi-recipient messages, content may remain until all relevant recipients have burned, expired, deleted, or otherwise satisfied the system's purge condition. The clearing process removes stored content and media files from active server storage, but message rows, delivery records, technical metadata, logs, and other non-content records may remain under this policy.

Burn-after-read is best-effort. It cannot prevent screenshots, screen recordings, photos of the screen, external recording, copying before deletion, notification previews, recipient-device backups, recipient misconduct, account compromise, or device-level bypasses. Cleared content is not retained long-term and backups roll over within 30 days. Lueurly does not promise immediate, irreversible, forensic, or recipient-device deletion. Data subject to a valid legal hold, court order, safety investigation, abuse report, payment dispute, or legal claim may be preserved to the extent permitted or required by law.

4. Backups and Logs

Database backups are retained on a 30-day rolling basis. Application logs are retained for 30 days. Web access logs are retained for 14 days.

Logs may include IP addresses, user agents, device identifiers, timestamps, and operational events needed for security, abuse prevention, debugging, and legal compliance.

5. Account Deletion

When you delete your account, Lueurly deletes or anonymizes account data and remaining content associated with the account within a reasonable period, subject to the short retention periods above and any legal, subscription, safety, dispute-resolution, abuse-prevention, or audit obligations that require limited retention. Data that must be preserved for a valid legal hold, court order, safety investigation, payment dispute, or legal claim may be retained for as long as reasonably necessary for that purpose.

6. Contact

For retention questions or deletion requests, contact:

[email protected]

The official version and controlling language of this document are governed by Section 27 of the Lueurly Common Terms of Use.

Account Deletion

1. In-App Account Deletion

You may request deletion of your Lueurly account through the in-app account deletion control currently located at:

Settings -> Delete Account

When you use that control, Lueurly records and processes your deletion request through its internal account-management systems. We may require reasonable authentication or other verification before completing a deletion request in order to protect against unauthorized account deletion.

2. What Is Deleted

Account deletion deletes or anonymizes account data and remaining content associated with your account, including account profile data, messages, exclusive media, pact-related account data where deletion is allowed, contact-sync hashes, friend and block data, device sessions, push tokens, preferences, pending scheduled sends, drafts, and Premium-dependent configurations tied to the deleted account.

Some content may also be removed from active storage because it is exclusively associated with your account.

3. Limited Exceptions

Some records may be retained where reasonably required for security, legal compliance, subscription verification, payment dispute handling, abuse prevention, dispute resolution, legal claims, or audit integrity. The normal retention periods are described in the Data Retention Policy:

  • burn-after-read content cleared within 1 hour after read and expiry;
  • contact hashes 90 days;
  • pact signing audit GPS coordinates 90 days;
  • login attempts 30 days;
  • audit logs 180 days;
  • web access logs 14 days;
  • application logs 30 days;
  • database backups 30-day rolling.

4. If You Cannot Access the App

If you cannot access the app, you may submit a verifiable deletion request by emailing [email protected] from the email address associated with your Lueurly account. We may request information reasonably necessary to verify account ownership, authenticate the request, prevent fraud or abuse, and protect the security of the account.

5. After Deletion

Deletion is intended to be irreversible. You may lose access to messages, pact records, Premium entitlement state inside Lueurly, friends, settings, and exports. Apple subscription management remains handled by Apple; deleting your Lueurly account does not necessarily cancel an active App Store subscription. Cancel subscriptions in your Apple Account settings.

Any pending scheduled message, future delivery, Premium-only setting, Light Up Together (Sync Open) configuration, Fading Light (burn-after-read) configuration, Trusted device binding (device-bound) configuration, anonymous-message setting, Keepsake (pact) audit setting, or other account-tied future action may be cancelled, disabled, deleted, anonymized, or not delivered after account deletion, except where Lueurly is required by law to retain a limited record.

The official version and controlling language of this document are governed by Section 27 of the Lueurly Common Terms of Use.

Children and 18+ Statement

1. Adults Only

Lueurly is for adults only. You must be at least 18 years old to create an account or use the service.

2. Not Directed to Children

Lueurly is not designed for, marketed to, or directed at children or minors. The service includes private messaging, user-generated content, synchronized message unlocking, pact signing, and Premium features that are intended only for adults.

Lueurly does not knowingly collect personal information from children under 13. If Lueurly obtains actual knowledge that it has collected personal information from a child under 13, Lueurly will take reasonable steps to delete, anonymize, or disable access to that information, except where limited retention is permitted or required by law for security, legal compliance, abuse prevention, or protection of users.

3. Age Check

Lueurly collects `birth_year` during registration or first SSO use to help enforce the 18+ requirement.

4. Underage Accounts

If Lueurly learns that an account belongs to a person under 18, Lueurly may suspend, disable, terminate, delete, or anonymize the account and related data as appropriate and as permitted or required by law. Underage users may not use Anonymous messages, Keepsakes (pacts), Light Up Together (Sync Open), or any other Lueurly feature.

5. Reporting

If you believe a minor is using Lueurly, or if you see content that exploits or endangers a minor, contact [email protected] promptly. Lueurly has zero tolerance for child sexual abuse material and may report apparent child exploitation to NCMEC and law enforcement where applicable.

The official version and controlling language of this document are governed by Section 27 of the Lueurly Common Terms of Use.