Privacy Policy for LuckyMe

1. What is Personal Data, and What Data Do We Process?

1.1 Definition of Personal Data

Personal data refers to any information that identifies or can be used to identify a natural person, such as name, surname, email address, telephone number, gender identity, mood, and any other information related to you (e.g., preferences, habits, or device information linked to your identity).

1.2 Types of Data Processed

We process two categories of data: user-provided data and automatically collected data.

1.2.1 User-Provided Data

This includes data you voluntarily provide to us through the App or other communication channels, such as:

• Optional data: Name, gender identity, mood.
• Data related to service use: Information provided when subscribing to the Premium version of LuckyMe (e.g., payment-related data, which is processed directly by the relevant application store (Google Play or Apple Store) and not stored by us).
• Communication data: Information you provide when contacting our support team via the Support Email.

1.2.2 Automatically Collected Data

When you visit, use, or browse LuckyMe, we automatically collect certain information that does not directly reveal your identity but helps us maintain the App’s security and improve its performance. This includes:

• Log and usage data: Service-related, diagnostic, usage, and performance information collected by our servers, such as your IP address, device information, browser type and settings, activity on the App (e.g., date/time of use, Content viewed, features accessed), system activity, error reports ("crash dumps"), and hardware configuration.
• Device data: Information about the device you use to access LuckyMe, such as device model, manufacturer, operating system, system version, App identification numbers, browser type and version, internet service provider/mobile operator, and IP address (or proxy server).
• Location data: Information about your device’s location (which may be approximate or precise, e.g., based on your IP address). We may use GPS or similar technologies to collect this data, but you can opt out by denying location access or disabling location settings on your device.
• Mobile device access data: If you use LuckyMe on a mobile device, we may request access to certain device features (e.g., camera, reminders, social media accounts) with your permission. You can modify these permissions in your device settings at any time.
• Push notification data: We may collect information about whether you enable or disable push notifications (used to send you Content reminders). You can disable push notifications in your device settings.

2. Purpose, Legal Basis, and Storage Period of Data Processing

We process your personal data only for specific, legitimate purposes and in compliance with applicable data protection laws. Below is a breakdown of the purposes, legal basis, and storage periods for each type of processing.

2.1 Provision of Requested Services

2.1.1 Purposes

We process your data to:

• Provide and maintain the services offered by LuckyMe (e.g., delivering Content, sending reminders, processing Premium subscriptions).
• Respond to your inquiries and provide customer support via the Support Email.
• Manage invoicing, collection, or follow-up for Premium subscriptions (note: payment data is processed by Google Play or Apple Store, not by us).
• Conduct statistics, studies, and research to evaluate the App’s services and respond to user needs.
• Ensure the proper provision of services and comply with legal obligations related to service provision.

2.1.2 Legal Basis

The legal basis for this processing is the performance of the contract between you and us (i.e., the provision of LuckyMe’s services, including Premium subscriptions) or the fulfillment of our legal obligations.

2.1.3 Storage Period

We retain your personal data for no longer than necessary to achieve the above purposes. This includes:

• For the duration of your use of LuckyMe (including the Premium subscription period).
• For the applicable statute of limitations period after you cease using the App (to comply with legal obligations, such as tax or contractual record-keeping requirements).

Once your data is no longer needed, we will delete it using appropriate security measures to ensure anonymization or complete destruction.

2.2 Research, Information, and Service Improvement (Legitimate Interest)

2.2.1 Purposes

We process your data (including user-provided data and automatically collected data) to:

• Conduct scientific and statistical research on user preferences, tastes, and habits to innovate and improve LuckyMe’s Content and services.
• Send you information about LuckyMe’s updates, promotions, or related activities via the communication channels you provided (e.g., email).

2.2.2 Legal Basis

The legal basis for this processing is our legitimate interest in improving the App and providing users with relevant information about our services.

2.2.3 Opt-Out Right

You may unsubscribe from promotional communications at any time by following the opt-out instructions included in each communication.

2.3 Third-Party Commercial Communications

If we intend to send you commercial communications from third parties related to the services you use (e.g., partner offers relevant to LuckyMe), we will first obtain your express consent.

2.3.1 Legal Basis

The legal basis for this processing is your express consent.

2.3.2 Opt-Out Right

If you have given consent, you may unsubscribe from third-party commercial communications at any time by following the opt-out instructions provided in each communication.

3. To Whom Do We Disclose Your Personal Data?

We treat your personal data with strict confidentiality and implement necessary security measures to protect it. We only disclose your data to third parties in the following cases:

3.1 Service Providers

We may share your data with third-party service providers who assist us in operating LuckyMe, providing services, or complying with legal obligations. These include:

• Payment processors (Google Play, Apple Store) for processing Premium subscription payments.
• Cloud storage and hosting providers (e.g., for storing App data and user information).
• Analytics providers (e.g., for analyzing App usage and improving services).
• Customer support tools (e.g., platforms used to respond to your inquiries).

We enter into written contracts with all such service providers, requiring them to protect your personal data and process it only in accordance with our instructions and applicable data protection laws.

3.2 Public Authorities and Legal Obligations

We may disclose your data to public administrations, courts, or other private entities if required by law (e.g., to comply with a court order, tax regulation, or other legal obligation).

4. Minors

LuckyMe’s services are intended for adults. We do not intentionally collect personal data from minors (individuals under the age of 18) without the express written consent of their parents or legal guardians.

If we become aware that a minor is using LuckyMe without parental/guardian consent, we will delete the minor’s data and may report the incident to the relevant authorities. If you suspect a minor has provided data to us without consent, please contact us via the Support Email.

5. International Data Transfers

LuckyMe is available in application stores worldwide, and the Responsible Party may be domiciled in a country outside your own. This may involve the international transfer of your personal data (e.g., to the United States or other countries).

We ensure that all international data transfers comply with applicable data protection laws and that your data is protected with adequate safeguards. This includes using:

• Standard contractual clauses (approved by data protection authorities) with our international service providers.
• Recognized data protection frameworks (e.g., the EU-U.S. Data Privacy Framework for transfers to the United States).

By using LuckyMe and accepting this Privacy Policy, you consent to the international transfer of your personal data as described above.

6. Your Rights Regarding Your Personal Data

Under applicable data protection laws, you have the following rights regarding your personal data:

6.1 Right to Access

You have the right to request confirmation of whether we are processing your personal data and, if so, to access the data (e.g., a copy of the data we hold about you).

6.2 Right to Rectification

You have the right to request the correction of inaccurate personal data or the completion of incomplete data.

6.3 Right to Deletion ("Right to Be Forgotten")

You have the right to request the deletion of your personal data, unless we are required by law to retain it or have a legitimate reason to continue processing it (e.g., to defend a legal claim).

6.4 Right to Restriction of Processing

You have the right to request that we restrict the processing of your data in certain cases, such as while we verify the accuracy of the data or the legitimacy of the processing.

6.5 Right to Object

You have the right to object to the processing of your data for reasons related to your personal situation, unless we have overriding legitimate interests (e.g., for legal defense) or are required by law to process the data.

6.6 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to request that we transmit this data directly to another data controller (where technically feasible).

6.7 Right to Withdraw Consent

If you have given consent for data processing (e.g., for third-party commercial communications), you have the right to withdraw this consent at any time. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

6.8 How to Exercise Your Rights

To exercise any of the above rights, please send a written request to the Support Email, including:

• Your full name and contact information.
• A copy of a valid identification document (e.g., ID card, passport) to verify your identity.
• A clear description of the right you wish to exercise and the data related to your request.

7. Data Protection Officer and Complaints

7.1 Contact for Data Protection Inquiries

If you have questions, concerns, or inquiries about this Privacy Policy or the processing of your personal data, please contact us via the Support Email.

For specific data protection-related issues, you may also contact our Data Protection Officer (DPO) via the following email address: [DPO Email Address].

7.2 Right to Lodge a Complaint with a Supervisory Authority

If you are dissatisfied with our handling of your personal data or our response to your request, you have the right to lodge a complaint with the data protection supervisory authority in your country of residence.

8. Security Measures

We take appropriate technical and organizational security measures to protect your personal data from alteration, loss, unauthorized access, or processing. These measures include:

• Encrypted data transmission (via HTTPS) for all communications between the App and our servers.
• Secure storage of data on password-protected servers with restricted access.
• Regular updates to security software and protocols to address emerging risks.
• Staff training on data protection and security practices.

While we strive to protect your data, no security system is completely infallible. We cannot guarantee absolute security, but we will take all reasonable steps to mitigate risks.

9. Third-Party Websites and Services

LuckyMe may contain links to third-party websites or services (e.g., social media platforms). This Privacy Policy does not apply to these third-party services. We are not responsible for the privacy practices or content of third parties, and we recommend that you review their privacy policies before using their services.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in applicable laws, our services, or data processing practices. The updated version will be posted on LuckyMe and will take effect immediately upon publication.

If the updates involve material changes to the purposes or legal basis of data processing (not previously disclosed in this Policy), we will notify you in advance via the communication channels you provided (e.g., email) to allow you to review the changes and exercise your rights if necessary.

11. Effective Date

This Privacy Policy is effective as of 2025-09-20.