Luki Privacy Policy
Last Updated: March 3, 2025
At Luki, we place the utmost importance on safeguarding your privacy and are unwavering in our commitment to protecting your personal information. We adhere to the highest standards of security and reliability to ensure that your data is handled with care and transparency. This Privacy Policy provides a comprehensive overview of how we collect, use, share, and protect your personal information, while ensuring that your rights are respected at all times. By using Luki’s products and services, you acknowledge and agree to the terms outlined in this Policy. If you do not agree with these terms, we kindly ask that you refrain from using our application. For any inquiries, concerns, or requests regarding your privacy, please contact us through the channels provided at the end of this document.
1. Introduction
Luki is deeply committed to protecting your privacy and has established a robust and comprehensive framework to ensure the security and integrity of your personal information. Our practices are guided by the following core principles:
This Privacy Policy applies to all Luki products and services. However, it does not cover third-party services or products that operate under their own separate privacy policies.
2. How We Collect and Use Your Personal Information
By using Luki’s products and services, you acknowledge and agree to the following practices regarding the collection and use of your personal information:
Range of Products and Services
The type and scope of personal information we collect may vary depending on the specific product or service you use. For detailed information about the data collected for each product or service, please refer to the relevant product or service description.
Utilization Across Features
Data collected through one feature or service may be utilized to enhance other areas of our platform. For example, information gathered from one feature may be used to personalize content, improve security measures, or optimize user profiles. If we intend to use your personal information for new or unrelated purposes beyond what was initially specified, we will notify you and seek your explicit consent before proceeding.
Ongoing Improvements and Information Adjustments
As part of our commitment to continuous improvement, we may introduce new features or enhance existing ones. This may require the collection of additional personal information or changes in how your data is used. You will be informed of such changes through updates to this Privacy Policy, in-app notifications, or other communication channels. Your data will only be collected and used with your explicit consent. If you have any questions or concerns during this process, please contact us through the provided channels, and we will respond promptly.
Special Notes on Data Collection and Usage
User Registration
To access and use Luki’s services, you must complete the account setup process. You are responsible for safeguarding your account credentials and should not share them with others.
Device ID and Unique Identifier
We use your device ID and unique identifier to ensure the secure and efficient operation of our software and services.
Permissions
To provide a richer user experience and ensure the full functionality of our services, we may request access to the following device features:
• Photo Library Access: To allow you to share images during chats or update your profile picture. This permission is only activated when you intentionally upload photos from your device’s library.
• Camera Access: To enable features such as taking and sharing photos or participating in live video calls. This permission is only active when you initiate a photo capture or start a video call.
• Audio and Video Access: To support video calls and audio recording. This permission is only used when you choose to make a video call or record audio.
• Bluetooth Access: To ensure a high-quality audio experience when connecting to Bluetooth devices. This permission is only activated when you pair your device with Bluetooth accessories.
• External Storage Access: To save or manage files such as photos and videos. This permission is only triggered when you save or download content.
• Advertising IDs: To optimize our marketing efforts and analyze campaign performance.
These permissions are only used after you provide explicit consent and can be managed or revoked at any time through your device settings.
Device Information
We automatically collect device details, such as your device ID, brand, model, operating system, IP address, and network type, to optimize app performance and ensure compatibility.
Data Collection for Analysis
We gather usage data and device logs to improve service quality and enhance user experience. This includes diagnostic data such as crash reports, hardware settings, and error logs.
For further analysis and to optimize marketing effectiveness, we may use third-party tools such as Appsflyer and Facebook Analytics. These platforms help us evaluate marketing strategies, track user behavior, and improve service performance. Data shared with these third parties is strictly limited to what is necessary for these purposes and is handled in compliance with applicable privacy laws.
Your Agreement and Our Commitment
By using Luki, you agree to the collection and use of your personal information as described above. We are steadfast in our commitment to protecting your privacy and ensuring that your data is handled securely and transparently. If you have any questions, concerns, or requests regarding your personal information, please do not hesitate to contact us.
Contact Information:
For privacy-related inquiries, please reach out to us at debendronathmanik@gmail.com.
Luki reserves the right to update this Privacy Policy as necessary to reflect changes in our practices or legal requirements. We encourage you to review this Policy periodically to stay informed about how we are protecting your information.
Thank you for trusting Luki with your personal information. We are dedicated to maintaining your trust and providing you with a safe and enjoyable experience.
3. Sharing, Transfer, and Disclosure of Your Personal Information
At Luki, we are committed to protecting your privacy and ensuring that your personal information is handled securely and responsibly. We do not share your personal information with external parties except in the following circumstances:
1. With Your Explicit Consent
We will only share your personal data with third parties if we have obtained your explicit consent. In such cases, you have full control over whether or not your information is shared, and you can withdraw your consent at any time.
2. Compliance with Legal Obligations
We may disclose your personal information when required to comply with applicable laws, regulations, or governmental requests. This includes situations where we are obligated to respond to legal proceedings, court orders, or administrative inquiries. In such cases, we will only provide the minimum amount of information necessary to fulfill the legal requirement.
3.Data Sharing Practices
We may share your personal information with third parties for legitimate business purposes, such as enhancing service functionality, preventing fraud, or providing customer support. All third-party recipients are bound by strict data protection agreements, ensuring your data is used only for specified purposes, protected with robust security measures, and handled in compliance with applicable privacy laws. If your data is transferred internationally, we implement adequate safeguards, such as Standard Contractual Clauses (SCCs), to ensure compliance. You have the right to object to data sharing or withdraw consent at any time by contacting us. We are committed to transparency and security in all data-sharing practices.
3. Collaboration with Authorized Partners
We may share your personal information with authorized partners who assist us in providing specific services or performing tasks on our behalf. These partners are strictly prohibited from using your information for any purposes other than those specified by us. Examples of such collaborations include:
￮ Technical Infrastructure: We work with third-party providers to ensure the smooth operation of our platform, including hosting, data storage, and server maintenance.
￮ Payment Processing: We partner with payment processors to facilitate secure transactions and manage billing.
￮ Marketing and Analytics: We collaborate with platforms such as Appsflyer and Facebook Analytics to analyze user behavior, optimize marketing campaigns, and improve service performance. These platforms help us evaluate the effectiveness of our advertising efforts and provide personalized user experiences.
4. Utilization of Personal Data for Business Objectives
We may disclose your personal information to external entities for valid business reasons, which include:
￮ Enhancing Services: Partnering with third parties to improve the quality and efficiency of our offerings.
￮ Combating Fraud: Collaborating with security experts to detect and prevent fraudulent behavior.
￮ Support Services: Engaging external providers to ensure prompt and effective customer assistance.
5. Data Transfers During Corporate Changes
In cases of mergers, acquisitions, or other corporate reorganizations, your personal information may be transferred to the new entity. We will ensure that your data remains protected under the terms of this Privacy Policy.
6. Agreements with Third Parties for Data Protection
All third parties who receive your personal information are bound by strict agreements that require them to:
￮ Use your data only for the purposes we specify.
￮ Implement strong security measures to protect your information.
￮ Adhere to relevant privacy laws and regulations.
7. Cross-Border Data Transfers
If your personal information is transferred to third parties in other countries, we will ensure compliance with applicable data protection laws. For example, when transferring data outside the European Economic Area (EEA), we will use appropriate safeguards, such as Standard Contractual Clauses (SCCs).
8. Your Control Over Data Sharing
You have the right to object to the sharing of your personal information in certain situations, particularly for marketing or analytics purposes. To exercise this right, please contact us through the provided channels.
By using Luki’s services, you acknowledge and agree to the sharing, transfer, and disclosure of your personal information as described above. We are committed to transparency and ensuring your data is handled with care and security. If you have any questions or concerns, please contact us.
9. Protecting Your Personal Information
We use industry-standard security measures to safeguard your data from unauthorized access, misuse, or loss. These measures include data anonymization, strict access controls, and regular staff training. If you suspect a security breach, please inform us immediately.
10. Managing Your Personal Information
You have the right to access, update, or delete your personal data. To do so, please contact us. Note that some data may remain in backup systems temporarily due to technical or legal requirements.
11. Legal Grounds for Data Processing and Your Rights
a. Legal Grounds for Data Processing
At Luki, we process your personal data in accordance with applicable privacy laws. The legal bases for processing include:
￮ Consent: We may seek your explicit consent to collect and use your personal data. You can withdraw your consent at any time.
￮ Contractual Necessity: Processing is required to fulfill a contract or agreement with you.
￮ Legitimate Interests: Processing is necessary for our legitimate interests, such as ensuring app security and improving user experience.
￮ Legal Obligations: Processing is required to comply with legal or regulatory requirements.
￮ Public Interest: Processing may be necessary for tasks carried out in the public interest, such as public health or safety.
b. Your Rights
Under applicable data protection laws, you have the following rights:
￮ Access: Request access to the personal data we hold about you.
￮ Correction: Request corrections to inaccurate or incomplete data.
￮ Deletion: Request deletion of your personal data in specific situations.
￮ Restriction: Request restrictions on the processing of your data.
￮ Portability: Receive your personal data in a transferable format.
￮ Objection: Object to the processing of your personal data, particularly for direct marketing.
￮ Withdrawal of Consent: Withdraw consent for data processing at any time.
￮ Complaint: Lodge a complaint with your local data protection authority if you believe your rights have been violated.
c. Compliance with International Privacy Laws
Luki complies with international privacy laws, including:
￮ GDPR: Applies to users in the EU and EEA.
￮ CCPA: Governs the privacy rights of California residents.
￮ LGPD: Applies to users in Brazil.
￮ PIPEDA: Applicable to users in Canada.
￮ VCDPA: Protects the privacy rights of Virginia residents.
￮ Other Laws: Additional privacy laws may apply depending on your location.
12. Privacy Rights for California Residents under the CCPA
California residents have the following rights:
￮ Know: Request details about the personal information we have collected, used, shared, or sold in the last 12 months.
￮ Delete: Request deletion of your personal data, subject to legal exceptions.
￮ Opt-Out of Sales: Opt out of the sale of your personal information.
￮ Non-Discrimination: Exercise your privacy rights without facing discrimination.
￮ Opt-Out of Targeted Advertising: Opt out of the sharing of your personal data for targeted advertising.
13. LGPD Compliance Notice (Applicable to Brazil)
￮ Access: Request information about the personal data we hold.
￮ Correction: Request corrections to inaccurate or incomplete data.
￮ Erasure: Request deletion of your personal data where legally permitted.
￮ Information: Know which organizations we share your data with and the reasons for doing so.
￮ Revoke Consent: Withdraw previously granted consent.
￮ Objection: Object to the processing of your personal data based on legitimate interests.
￮ Data Transfer: Request the transfer of your personal data to yourself or a third party.
￮ Complaint: File a complaint with the National Data Protection Authority (ANPD).
For users in Brazil, Luki complies with the LGPD. Your rights include:
￮ Access: Request information about the personal data we hold.
￮ Correction: Request corrections to inaccurate or incomplete data.
￮ Erasure: Request deletion of your personal data where legally permitted.
￮ Information: Know which organizations we share your data with and the reasons for doing so.
￮ Revoke Consent: Withdraw previously granted consent.
￮ Objection: Object to the processing of your personal data based on legitimate interests.
￮ Data Transfer: Request the transfer of your personal data to yourself or a third party.
￮ Complaint: File a complaint with the National Data Protection Authority (ANPD).
14. Exercising Your Opt-Out Rights
You have the right to opt out of specific data processing activities, such as:
￮ Data Sharing: Choose not to share your personal data with third parties for analytics or marketing purposes.
￮ Withdraw Consent: Withdraw consent for data processing at any time.
￮ Data Analysis: Opt out of data analysis processes used to improve services or personalize your experience.
To exercise these rights, please contact our privacy team at debendronathmanik@gmail.com.
15. Commitment to Compliance
Luki is committed to respecting your privacy rights and complying with applicable privacy laws. We continuously monitor and update our practices to ensure compliance with evolving regulations.
16. Protection of Minors' Personal Information
Our services are not intended for users under 18. We do not knowingly collect data from minors and will remove such information if discovered.
17. Data Protection Officer (DPO)
Luki is committed to safeguarding your privacy. To ensure compliance with data protection laws, including the GDPR, CCPA, and other regional regulations, we have appointed a dedicated Data Protection Officer (DPO), Ethan Walker. The DPO oversees all aspects of personal data protection, including its collection, use, storage, and sharing.
If you have questions, concerns, or requests regarding your personal data, or if you wish to exercise your privacy rights, you can contact our DPO directly. Ethan Walker is available to provide clarity on our data practices, address privacy-related issues, and resolve concerns promptly and effectively.
For inquiries, please email our DPO at debendronathmanik@gmail.com. To ensure a swift and accurate response, please include detailed information about your request or concern.
18. Controller Information
Luki acts as the data controller for your personal information in connection with our products and services. As the controller, we determine the purposes and methods of processing your data, ensuring compliance with applicable privacy laws and regulations.
We are committed to transparency and accountability. Whether you need information about how your data is used, wish to access your personal information, or seek clarification on our privacy practices, our team is here to assist you.
For any inquiries related to your personal data, please contact us at debendronathmanik@gmail.com. We will review your request and respond in a timely manner.
Address:
Bangladesh, Sadi, Mandalerhat-5620, Ulipur, Kurigram
By using Luki’s services, you acknowledge that we are committed to protecting your privacy and handling your personal information responsibly. If you have any concerns, we encourage you to reach out to us.
19. Controller Information
Luki is the data controller responsible for managing your personal information. For inquiries, please contact us at debendronathmanik@gmail.com.
20. Contact Us
For questions, comments, or suggestions regarding this Privacy Policy or our data practices, please contact us at debendronathmanik@gmail.com. We strive to respond to all requests within 15 days.
By using Luki’s products and services, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy. Thank you for trusting Luki with your privacy.