Privacy Policy
This Privacy Policy outlines the internal data handling protocols, information flow practices, and user data protection standards applied by Luka (“we”, “us”, “our”), the operator of “Luka — Small friend, Big Happiness”, in connection with all user access to and engagement with the Luka application and its associated service offerings (collectively, the “Platform”). Individual users of the Platform are addressed here as “you” and “your”. Interacting with or utilizing any part of the Platform constitutes your voluntary acknowledgment and affirmative consent to the data collection, usage, retention, and protection practices defined below. This document has been drawn up by reference to applicable U.S. federal privacy standards and to the California Consumer Privacy Act and California Privacy Rights Act (CCPA/CPRA).
Luka is run for users in the United States. We do not market, distribute, or tailor the service for people outside the U.S.; if you are reading this Policy from another country, please understand that your access is on your own initiative, and your information will continue to be handled under this Policy and the U.S. law that applies to it.
1. Overview of Information Flow & Data Collection Mechanisms
The Platform operates through standardized data workflows that capture two primary streams of user information across all service interactions: information actively submitted by users during platform engagement, and contextual data passively captured through automated system protocols to sustain platform functionality. Data collection is confined to what is reasonably necessary to operate, maintain, and secure the Platform. All collected information is categorized as either user-provided personal identifiers or passive operational data, for consistent privacy management.
Active user-submitted information includes all profile-related identifiers, custom user content, account credential data, and textual or interactive material voluntarily shared while utilizing platform features. This category also encompasses all user-initiated communications submitted through platform support or interactive channels. Passively collected operational data includes device metadata, access session metrics, platform interaction patterns, network connection parameters, and system log data generated during every platform visit. Additionally, all user inputs, system prompts, and algorithmic interactions tied to the platform’s automated and intelligent processing systems are captured as operational interaction data, to refine service stability and algorithmic performance.
Three further streams flow from the Platform’s interactive components:
- Interactive exchange data — electronic messages addressed to a fellow User, contact-exchange requests and their responses, the record of participation in matches and other joint activity, and whichever profile particulars you elect to render visible across the user base.
- Profile and engagement records — the display name you adopt, the personalisation settings you choose, a history of your engagement, the tally of days you and your companion have shared, tallies of matches and of milestones reached, together with the balance of virtual items (such as Sparks, gifts, Plus Pass membership and visitor-access subscription entitlements) standing to your platform access profile, and your Bond progress and contact-exchange records.
- Visual asset data — images you elect to introduce, and milestone or keepsake visuals assembled for you inside the Platform.
Biometric identifiers, facial geometry, and voiceprints fall outside what is captured; so does position, save where Section 2 describes it. Neither an address book nor a contact list is requested by the Platform, captured by it, or uploaded to it.
Material to be withheld by you. Government-issued numbers, the particulars of any account you maintain with a financial institution, records touching health or treatment, the street on which you actually reside, and any credential that grants access to anything: all of these are to be kept out of the intelligent processing features and out of whatever you transmit to a fellow User. Anything of comparable sensitivity belongs in the same list.
2. Device-Level Features and Authorisations
Luka asks for device access only when a feature needs it. Each permission is yours to grant, withhold, or revoke in your device settings, and withholding one affects that feature alone. Because the Android app is distributed through Google Play, Android may also show its own privacy indicators and controls; those are provided by the operating system, not by Luka.
- Photos. When you choose a photo for your profile, a chat, or a post, Luka opens Android's system photo picker. The picker gives Luka only the item you select; it does not let Luka scan or index the rest of your gallery. Luka does not write to your photo library. On Android versions without the system picker, the system's legacy picker is used and only the selected item is returned.
- Camera. Luka asks for the camera when you open the AR play view, take a photo in the app, or join a video call. AR play overlays your companion on the camera preview on your device; those camera frames are processed locally and are not uploaded to Luka's servers. Video-call frames are carried only to the other participant through the call service.
- Microphone. Luka asks for the microphone when you record a voice message or join a voice or video call. Audio is used for that message or call, including any transcript requested by a recipient, and for safety review where necessary, and for no other purpose.
- Motion. Luka reads the device's motion sensor when you shake your phone to play with your companion. Motion readings are processed on your device and are not used for location or advertising.
- Push notifications. If you allow them, Luka sends reminders, pet activity, match and message alerts, and service notices. You can turn them off at any time in device settings.
- Location. Luka asks for location only when a feature depends on it, such as showing people near you and your distance to them. We use approximate, rough location (city or neighborhood level), not your precise GPS coordinates, for that feature alone. The permission is optional: if you decline, you can enter a city, neighborhood, or ZIP code by hand and the feature runs on that entry. Luka does not read location in the background or after the app is closed.
3. Authorized Data Usage & Operational Processing
All collected user information is processed only for legitimate operational, security, and service enhancement purposes that directly support platform delivery. We utilize stored user data to administer secure account access, validate user identity, sustain core platform operations, resolve user inquiries, and maintain consistent service functionality across all user interactions. Data processing activities further include anonymous trend analysis, service performance optimization, algorithm refinement for automated platform features, and proactive security monitoring to mitigate unauthorized access, fraudulent activity, and platform misuse.
Delivery of your messages to the addressees you name, and display of the profile entries you have chosen to put on view, constitute a further purpose. So does the running of matches and other joint activity — including Nearby discovery, Feed posts, Quick Pick, Love Ring, and Bond and contact-exchange records — together with the award and exhibition of virtual items such as Sparks, gifts, Plus Pass membership, and visitor-access subscriptions. So does the operation of voice messages and video calls, including the metering of call minutes and their billing. So does the keeping of your companion — the pet that lives in the application — its progress, and the record of the days you have shared with it. So does the assembly of milestone and keepsake visuals from your records and submissions, AR play, and the data needed to keep the Home Screen widget in step. So does the attribution of how an installation came about and the measurement of advertising performance. So, finally, does the weighing of reports lodged by Users and the consideration of material or conduct running counter to our operating rules or to law, whereupon whatever measure strikes us as fitting may be adopted at discretion. Legal claims brought, defended or answered, and enforcement of the terms upon which the Platform is furnished, account for the remainder.
Sale of personal information does not occur here, nor does its rental or its lease, to an external party or to anyone else, under any circumstance whatever. Cross-context behavioural advertising receives nothing. Targeted advertising is not conducted at all. Profiling directed at decisions of legal or similarly significant effect is not undertaken.
4. Controlled Data Sharing & Third-Party Limitations
User personal data is only shared with external third-party entities under limited circumstances. Disclosure may be made to service providers and operational partners delivering essential backend, technical, analytical, or measurement support for the Platform — including analytics and attribution providers such as AppsFlyer, and push and real-time communication providers — and such parties are engaged on terms that bind them to confidentiality and confine their use of the data to the work they perform for us.
User data may also be disclosed when legally required to comply with governmental regulatory requests, court mandates, or federal and state legal obligations. Disclosure may additionally occur to protect the legal rights, property, and safety of our platform, users, and the general public. De-identified, aggregated user data that cannot be linked to any individual user may be used for internal analytics and service reporting.
Exposure across the user base. The name you display, the particulars on your profile, the messages you exchange, the contact details you choose to exchange, the entries you make visible, the virtual items you send or exhibit — whatever of these you place on view through an interactive component travels to the Users you have named, or to whoever else has a part in that component. It then lies open to them to read, to retain, to capture as an image, and to circulate onward. What they do with it after that is past our reach and no responsibility of ours. Once a recipient holds something, it is not open to us to recall it.
Practices belonging to others. How Google handles data — Google Play being the channel through which the application is distributed — and how any sign-in service you choose to use handles it, are matters for their own policies. Those policies are not ours to direct, and no responsibility under them falls on us.
5. Intelligent System Data Handling Protocols
The Platform integrates automated and intelligent processing systems to deliver enhanced interactive service capabilities. User inputs and interactions passing through those systems are handled under this policy. Generation of platform outputs, responsiveness of the system, accuracy of the algorithms and refinement of the service experience account for the processing in the first instance. Threat screening, abuse detection, fault diagnosis, quality assessment and the general betterment of the Platform account for it thereafter. A portion of it may be handled for us by whoever supplies the models or the infrastructure.
The Platform’s intelligent feature is opt-in. Where the optional AI insights feature has been turned on, the photographs inside the posts you have published are sent to a third-party model provider — OpenAI, through the Microsoft Azure OpenAI Service — so that a short headline and the note beneath it may be written for your card. Turned off, nothing is submitted. That feature reads no camera roll, no private message, no precise location, and no contact; what passes through it is not used to train general-purpose models, and it is kept no longer than the feature has use for it.
Access stands narrowed. Three occasions permit authorised personnel, few in number, to look at an input or an output: an abuse or safety question wanting investigation, a support request wanting settlement, and a legal requirement wanting compliance. Outward distribution for commercial modelling does not occur, nor does any transfer to a data broker. Users acknowledge that intelligent system outputs are algorithmically generated for platform convenience only, and all associated data processing is a necessary component of platform service delivery.
6. Closure of Your Platform Access Profile
A self-service closure control resides within the settings area of the Platform, by which your platform access profile may be expunged permanently, upon your own initiative and at whatever moment you elect, with no need to correspond with us and no need for any procedure outside the application. A recovery window of seven (7) days follows a closure request: signing back in during that window, or choosing Keep my account on the countdown screen, calls the closure off, and once the window has elapsed the closure is carried out. Removing the application from your device, of itself, expunges nothing.
Closure, once carried out, admits of no reversal. Four things lie beyond its reach: records we have a right or a duty to keep, for whatever reason — legal, fiscal, security, anti-fraud, a dispute, or enforcement — copies held in backup or archive until the ordinary cycle overwrites them, material already sent by you to a fellow User which now rests with that person, and aggregates or records stripped of identifiers from which nobody can be made out. Every virtual item, balance and membership entitlement attaching to the profile is extinguished with it.
7. Data Retention & User Controlled Data Lifecycle
A structured data retention lifecycle is maintained, designed to preserve user data only for the duration required to fulfill operational, legal, and security obligations. Active account data is retained for the full duration of a user’s active platform membership. Operational logs, session data, and algorithmic interaction records are retained for a limited operational window before de-identification or deletion.
Upon a valid request for data removal or profile closure, identifiable personal data is erased from active platform systems, save where retention is required by law or is necessary for compliance, dispute resolution, security review, anti-fraud purposes, or the establishment or defence of a legal claim. Residual copies may persist within backup systems until overwritten in the ordinary cycle.
Duration is governed by four rules of thumb. A profile record lasts as long as the profile does, plus a short tail thereafter across which closure is finished off and disputes are settled. An operational or diagnostic log lasts a rolling window set by what security and troubleshooting actually demand. Correspondence with support lasts until the matter, and anything growing out of it, is done with. An input or output of the intelligent processing features lasts no longer than those features have use for it.
8. Data Security Safeguards & Risk Mitigation
We maintain a layered security framework combining technical, administrative, and operational safeguards directed at protecting stored user personal data from unauthorized access, modification, disclosure, or destruction. These safeguards may include data encryption, role-based internal access restrictions, and security monitoring. Personnel holding authorised access are subject to confidentiality obligations.
No digital storage or data transmission system can guarantee absolute security, and no such guarantee is given here. Anything transmitted to the Platform travels at your own risk. The safekeeping of your access credentials and of the device upon which you use the Platform rests with you.
9. California Resident Privacy Rights (CCPA/CPRA) & User Autonomy
Residents of California possess statutorily protected consumer privacy rights in respect of personal data collected and maintained by our platform, grounded in the CCPA and the CPRA. These rights include the ability to access records of collected personal data, to request correction of inaccurate stored information, to pursue deletion of eligible personal data, and to obtain disclosure of data sharing practices.
Sale and sharing. The statutory opt-out presupposes an underlying activity to opt out of. Here that activity is absent: nothing is sold, and nothing goes out for cross-context behavioural advertising. A request aimed at such an opt-out therefore meets nothing, and the same holds for a preference signal arriving from a browser or a device.
Sensitive personal information. A right of limitation under California law answers to uses and disclosures of a particular description. None of that description takes place here, and nothing of the kind is turned to account in building a picture of what sort of person you are.
Automated decision-making. No automated processing is turned to decisions that carry legal consequences, or consequences of a similarly significant order, for you.
Categories collected and disclosed across the preceding twelve (12) months. Six categories describe the whole of it. First, identifiers — an email address, an IP address, a device identifier, and an advertising identifier. Second, activity upon an electronic network, meaning records of interaction and measurements of performance. Third, whatever Users have submitted by way of content or communication. Fourth, visual material, reaching no further than images introduced by you and visuals assembled on your behalf. Fifth, approximate location (city or neighborhood level), taken through the device authorisation described in Section 2 and from no other source. Sixth, inferences resting on the five preceding. Providers of hosting, of storage, of analytics and attribution, of diagnostics and of security receive these categories; no recipient beyond them does.
Exercising a statutory privacy right brings no penalty with it: service is not curtailed, no feature is withdrawn, and nothing is refused you for having asked. Inquiries and formal requests of the California kind go to lukaandfeedback@lukaluv.com. Nothing is acted upon until identity has been settled, and a request unusual or sensitive in character may call for evidence past what is already held. The period for resolution, and the footing on which resolution proceeds, are those the statute lays down. Three grounds permit refusal, whether entire or partial — an exemption that reaches the request, an identity that cannot be settled, and a request plainly excessive, or one without foundation. An agent acting under written proof of authority may proceed for you, and confirmation may be sought from you directly.
10. Privacy Rights in Other States
Comprehensive consumer privacy statutes stand enacted in a number of states beyond California, and residents there may hold rights of a familiar cast: to reach what is held, to have it put right, to have it deleted, to obtain a portable copy, and to stand aside from advertising that is targeted, from any sale of personal data, and from particular kinds of profiling. Not one of those last three activities is carried on here. A request directed to lukaandfeedback@lukaluv.com is dealt with as the statute governing you requires; where that statute gives an appeal against a refusal, a reply to the answer you receive lodges it, and the attorney general of your state remains available thereafter.
11. Age Verification & Minor Data Protection
The Platform is exclusively designed and intended for use by adult individuals aged 18 years or older. We do not knowingly collect, store, or process personal data belonging to minors under the age of 18. Where the presence of minor data comes to our notice, the associated records may be deleted and the platform access profile closed, as we judge fit, without notice. Any party identifying minor data presence on the Platform may notify us at lukaandfeedback@lukaluv.com.
An absolute bar stands against material that shows a person under eighteen (18) or puts such a person in sexual terms. Four steps lie open to us should any surface: the material taken down, the platform access profile behind it closed, the surrounding records preserved, and any report the law demands of us made to the competent authorities.
12. Policy Amendments & Transparency Updates
We reserve the right to amend, update, or revise this Privacy Policy at any time to reflect changes in platform data workflows, security protocols, industry best practices, or regulatory privacy compliance requirements. All policy revisions will be posted directly within the Platform. Continued platform usage following the publication of updated policy terms constitutes user acceptance of all revised data handling practices.
13. Privacy Inquiries & User Support
All questions, formal inquiries, data right requests, and privacy-related correspondence may be directed to our dedicated privacy support channel at lukaandfeedback@lukaluv.com. Valid user privacy submissions are answered in accordance with applicable U.S. federal and state privacy regulations.