Privacy Policy

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register for the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• •names
• •email addresses
• •passwords
• •contact preferences
• •contact or authentication data
• •audio recordings
• •text input
• •therapy sessions

Sensitive Information.

We may process sensitive information when necessary with your consent or as otherwise permitted by applicable law. We process the following categories of sensitive information:

• •health data
• •user-submitted reflection or therapy-related data (which may incidentally contain sensitive information)

Payment Data.

We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is handled and stored by [Payment Processor Name]. You may find their privacy notice link(s) here: [Privacy Notice Links].

Social Media Login Data.

We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain information about you from your social media account, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

Application Data.

If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• •
  Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• •
  Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's microphone, calendar, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• •
  Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of our application(s) you accessed.
• •
  Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

• •
  Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• •
  Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• •
  Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• •
  To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• •
  To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• •
  To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• •
  To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• •
  To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• •
  To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• •
  To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• •
  To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• •
  To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
• •
  Generate therapy session summaries. To process session recordings and notes in order to provide users with AI-generated summaries and insights.

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• •
  Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• •
  Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• •
  Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

  • •Analyze how our Services are used so we can improve them to engage and retain users
  • •Diagnose problems and/or prevent fraudulent activities
  • •Understand how our users use our products and services so we can improve user experience
• •
  Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• •
  Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• •If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• •For investigations and fraud detection and prevention
• •For business transactions provided certain conditions are met
• •If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• •For identifying injured, ill, or deceased persons and communicating with next of kin
• •If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• •If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• •If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• •If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• •If the collection is solely for journalistic, artistic, or literary purposes
• •If the information is publicly available and is specified by the regulations
• •Disclosure of de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers.

We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The third parties we may share personal information with are as follows:

• •
  AI Service Providers

  • •Google Cloud AI
• •
  Allow Users to Connect to Their Third-Party Accounts

  • •Google account and Apple account
• •
  Cloud Computing Services

  • •Google Cloud Platform
• •
  Functionality and Infrastructure Optimization

  • •Cloud Functions for Firebase and Cloud Storage for Firebase
• •
  Invoice and Billing

  • •Stripe
• •
  User Account Registration and Authentication

  • •Google OAuth 2.0
• •
  Website Hosting

  • •Vercel
• •
  Website Testing

  • •TestFlight

We also may need to share your personal information in the following situations:

• •
  Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics tracking for this site by visiting https://tools.google.com/dlpage/gaoptout.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

Our Services include products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide innovative solutions. The terms in this Privacy Notice govern the use of AI Products within our Services.

Use of AI Technologies

Our AI Products are provided through third-party service providers ("AI Service Providers"), including Google Cloud AI. Your input, output, and personal information will be shared and processed by these AI Service Providers to enable the use of AI Products for the purposes outlined in "WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?". You must not use AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed to perform the following functions:

• •AI document generation
• •AI applications

How We Process Your Data Using AI

All personal information processed using AI Products is handled in line with this Privacy Notice and our agreements with third parties, ensuring high security and safeguarding personal information for data safety.

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture, as well as other information you choose to make public on such social media platform.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly solicit data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at info@lusaea.com.

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent:

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications:

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information:

If you would at any time like to review or change the information in your account or terminate your account, you can:

• •Contact us using the contact information provided
• •Log in to your account settings and update your user account

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at info@lusaea.com.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there is not yet an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?".

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

Additional Collection Scenarios

We may collect personal information from you in additional scenarios, such as when you contact us for customer support, participate in surveys, or inquire about our services. This information is collected and processed in accordance with this Privacy Notice.

Retention and Usage Purposes

We use and retain the personal information we collect (categories A, B, H, L) for the purposes outlined in this Privacy Notice. For detailed information about how we use your personal information, please refer to the section "HOW DO WE PROCESS YOUR INFORMATION?".

Sources of Personal Information

For information about the sources from which we collect personal information, please refer to the section "WHAT INFORMATION DO WE COLLECT?".

How We Use and Share Personal Information

For information about how we use and share personal information, please refer to the section "HOW DO WE PROCESS YOUR INFORMATION?".

Do We Share Information with Others?

We may disclose your personal information to our service providers under contract, as described in the section "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?". We may use your personal information for internal business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" your personal information.

We have not sold or shared personal information for business or commercial purposes in the last twelve (12) months. We have disclosed the following categories of personal information for business or commercial purposes in the last twelve (12) months:

• •Category A. Identifiers.
• •Category B. Personal information as defined in the California Customer Records law.
• •Category H. Audio, electronic, visual, and similar information.

For more information about the categories of third parties with whom we share personal information, please refer to the section "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?".

Your Rights

You have rights under US state data protection laws. These rights are not absolute and may be declined in certain cases. In general, you have the right to:

• •Right to know whether personal data is being processed.
• •Right to access personal data.
• •Right to correct inaccuracies.
• •Right to request deletion of personal data.
• •Right to obtain a copy of previously shared personal data.
• •Right to non-discrimination for exercising rights.
• •Right to opt out of processing for targeted advertising, sale of personal data, or profiling.

Additional rights may apply depending on your state of residence. These may include:

• •Right to access categories of personal data processed (e.g., Minnesota).
• •Right to obtain a list of third parties with whom personal data has been disclosed (e.g., California, Delaware, Maryland).
• •Right to obtain a list of specific third parties with whom personal data has been disclosed (e.g., Minnesota, Oregon).
• •Right to review, understand, question, and correct how personal data has been profiled (e.g., Minnesota).
• •Right to limit use and disclosure of sensitive personal data (e.g., California).
• •Right to opt out of the collection of sensitive data and personal data from voice or facial recognition features (e.g., Florida).

How to Exercise Your Rights

To exercise your rights, you can:

• •Visit https://lusaea.com/contact
• •Email us at info@lusaea.com
• •Refer to contact details at the bottom of this document

An authorized agent can make a request on your behalf, but proof of valid authorization may be required, and requests without such proof may be denied.

Request Verification

Personal information provided in your request will be used for verification. If we cannot verify your identity from existing information, we may request additional information for security or fraud-prevention purposes. For requests submitted through an authorized agent, additional information and a written, signed permission from you may be required.

Appeals

If your request is declined, you can appeal by emailing info@lusaea.com. We will provide a written explanation of the reasons for the decision. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?".

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: https://lusaea.com/contact