Lueurly · Legal Center

Last updated 2026-06-17 · v1.1

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) runs on infrastructure operated by us under lumoraworks.uk. This is our own operational infrastructure, not a third party. The iOS app pins TLS connections to lumoraworks.uk.

Lueurly is not offered to, and is not targeted at, users in the European Union, European Economic Area, United Kingdom, Switzerland, or South Korea. Those regions are excluded through App Store Connect geo-restriction and operational controls. GDPR, UK GDPR, the Digital Services Act, and the Korean Location Information Act do not apply to the service.

2. Data We Collect

We collect and process only the categories described below.

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 Sync OpenLatitude, longitude, and accuracy in metersOnly when you manually check in for Sync OpenMulti-participant same-place unlock; check-in state may be broadcast in real time to participants in the same message
Location for pact signing audit`gps_lat`, `gps_lng`Only when you sign a pact and the Premium audit-location option is enabledPact signing audit metadata
IP for pact signing auditPublic IP captured from request headersPact signingPact signing audit metadata
User-generated contentText, voice files, photos up to 9, wax seal choice, replies, chat threads, pact content and signaturesWhen you create, send, receive, reply to, or sign contentCore messaging and pact features
Message feature flagsBurn-after-read duration, device-bound status, Sync Open status, scheduled delivery time, anonymous status, E2EE 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 email addresses only; we do not store plaintext contact email, phone number, or name for contact syncOnly after your express consentFinding registered friends and mutual matches
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

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 useSync Open check-in
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 GPS check-in, you may choose not to use that feature or withdraw the relevant permission.

This section describes our operational reasons for processing. It is not a GDPR legal-basis notice because Lueurly is not offered to users in the EU, EEA, UK, or Switzerland.

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 use message content and feature flags to deliver messages, schedule delivery, manage Sync Open, apply device-bound restrictions, operate E2EE, and support burn-after-read.

We use GPS coordinates only in two contexts: manual Sync Open check-in and optional Premium pact-signing audit. We do not continuously track location.

We use pact audit IP, GPS where enabled, device, and timestamp metadata as supporting evidence of signing intent and audit history.

We use contact hashes only to match registered users. We do not upload or store plaintext contact names, phone numbers, or contact email addresses for contact sync.

We use Firebase 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 dataServer hostingGermany
Resend, through an internal relayRecipient email address and email contentsTransactional and notification email deliveryUnited States

Lueurly's backend (API, media, notification, authentication, and related server endpoints) runs on infrastructure operated by us under lumoraworks.uk. This is our own operational infrastructure, not a third party. The iOS app pins TLS connections to lumoraworks.uk.

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

7. Storage Location and International Transfers

Your data is stored and processed on servers located in Germany (Hetzner Online GmbH, Nuremberg, Bavaria). Lueurly's backend (API, media, notification, authentication, and related server endpoints) runs on infrastructure operated by us under lumoraworks.uk. This is our own operational infrastructure, not a third party. The iOS app pins TLS connections to lumoraworks.uk. Lueurly is operated from Taiwan. By using the service, you consent to your data being transferred to and processed in Germany and other countries where our processors operate, such as the United States for email delivery through Resend.

This disclosure is provided for transparency. Lueurly is not established in the EU and does not submit to GDPR by using German hosting.

8. Retention

We retain data according to the verified retention schedule below:

DataRetention
Burn-after-read content, including text, E2EE payload, photos, and voice filesCleared from the server no later than 1 hour after read and expiry
Contact hashesDeleted after 90 days without update
GPS check-in coordinates, participant coordinates, and Sync Open anchor coordinatesCleared 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; erased when the account is deleted

Burn-after-read is best-effort. Lueurly cannot prevent recipients from taking screenshots, screen recordings, photos of the screen, or other external copies. Cleared burn-after-read content is not retained long-term, and backups roll over within 30 days.

9. Your Choices and Rights

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

You may delete your account in the app through Settings -> Delete Account. Account deletion triggers `POST /users/me/delete` and erases account data and exclusive media, subject to short retention needed for legal, security, subscription, or audit purposes described in this policy.

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

You may export messages through `GET /export/messages`, export pacts through `GET /export/pacts`, and export pact PDFs where available. Lueurly does not currently provide a single complete machine-readable account export endpoint.

You may delete contact-sync hashes through `DELETE /contacts/sync`, 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.

11. Security

Lueurly uses HTTPS/WSS, certificate pinning, E2EE using Curve25519, HKDF, and AES-GCM, server-side AES-GCM media encryption, Argon2id password hashing, Keychain session storage, and device/security audit controls.

No service can guarantee perfect security. You are responsible for keeping your account credentials and trusted devices secure.

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. If we learn that an underage account exists, we will terminate and delete it.

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]

This document is the legally binding version. Translations are provided for convenience only; in case of conflict, the English version prevails.