LumiUP Privacy Policy
Effective Date: September 6, 2025
Wilpuzzle Inc. (“we,” “us,” or “our”) values your privacy. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use LumiUP (the “App”), as well as the rights you may have.
1. Information We Collect
When you use the App, we may collect the following information:
Account Information: Email address, display name, avatar, and birthday.
App Usage Data: Luck points, daily motivation view status, inspiration feature usage, wish feature usage, and records of posts and interactions on the starry-sky page.
Region Information: The region you choose during registration or in your profile (not precise geolocation; you may choose freely).
Subscription Information: Subscription records processed via the Apple App Store (payments are handled by Apple; we do not store your payment card details).
Device & Log Information: App version, device model, crash logs, and basic access records (such as IP address and access time) for security and performance.
Communications: Your contact details and message content when you reach out via form or email.
User-Generated Content (UGC): Text, images, and related metadata that you voluntarily post in the starry-sky page or other features.
Sensitive data we do not collect: We do not collect government ID numbers, full financial account details, biometric templates, or precise geolocation, among other sensitive personal information.
2. How We Use Your Information
We use the information we collect to:
Create and manage your account to ensure smooth login and profile maintenance.
Provide core features, including daily motivation, inspiration, starry-sky interactions, wish features, and subscription benefits.
Personalize and improve the App based on usage to optimize experience and features.
Communicate and support, including responding to inquiries, processing requests, and sending necessary service notices.
(If applicable) Push notifications, with your consent, for daily motivation or service updates.
Security and compliance, including monitoring system operations, preventing abuse, and meeting legal obligations.
3. Third-Party Services
Firebase (Google LLC): Used for authentication (Sign in with Apple, Sign in with Google, and email login), database, and necessary backend services.
Email sign-in requires verification; only valid emails can complete registration and use.
(If enabled) We may use Firebase’s analytics capabilities to understand usage and improve features.
Apple In-App Purchase (IAP): Used for subscription and payment processing. All payment flows are handled by Apple; we do not store your payment card details.
4. Data Retention and Deletion
We retain information only for as long as necessary to fulfill the purposes described above or as required by law.
Unverified email accounts will be automatically deleted after a set period and will not be retained long term (this does not apply to Apple/Google sign-in accounts).
When you request account deletion, your account information, posted content, wish records, and other related data will be deleted together.
We process deletion requests within a reasonable time (typically within 7 days).
5. Your Rights
Depending on your jurisdiction, you may have the right to:
Access, correct, or delete your personal data by contacting us at any time.
Withdraw consent for optional features (e.g., inspiration, starry-sky interactions, wish features) in-app or by contacting us.
Delete your account at any time; we will process it within the timeline above.
Data portability: Where applicable, you may request that we export or transfer your personal data to a third party.
Regional differences: Your specific rights may vary by jurisdiction.
Response timelines and appeals: We will respond to privacy requests within legally required timelines (e.g., generally 30 days in Canada; generally 45 days in California, with possible lawful extensions and notice). To protect security, we may require identity verification. We may limit clearly unfounded or excessive requests as permitted by law. If you are unsatisfied with our response, you may lodge a complaint with your local authority (e.g., Canada’s OPC, Québec’s CAI, or California’s CPPA).
6. Children’s Privacy
The App is intended for users aged 13 and above. We do not knowingly collect personal information from children under 13. If we discover that a user under 13 registered without parental or guardian consent, we will take steps to delete the account and related data.
If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us immediately so we can delete it. Certain jurisdictions may require a higher minimum age (e.g., 16); we will comply with applicable local laws.
7. Information Security
We implement reasonable and appropriate technical and organizational measures to safeguard your information, including encryption in transit and at rest, access controls, least-privilege authorization, audit logging, and backups. However, no online service can guarantee 100% security. If a security incident occurs that may pose significant risk to you, we will fulfill our legal notification obligations.
8. Cross-Border Processing and Storage
Your information may be processed and stored in Canada, the United States, or other jurisdictions where our service providers operate. For personal information collected in Québec, we will assess cross-border transfer risks and adopt contractual and technical safeguards (e.g., data processing agreements, encryption, least-privilege access) in accordance with applicable laws (such as Québec’s Law 25). At collection or upon request, we will inform you if information may be transferred outside Québec.
9. No “Sale” or “Sharing” and Global Opt-Out Signals
We do not sell your personal information and do not “share” it for cross-context behavioral advertising (as defined by applicable laws). If our practices change in the future, we will provide a clear opt-out mechanism and, where required, recognize universal opt-out signals (e.g., Global Privacy Control, GPC).
10. Cookies and Mobile SDKs
We may use strictly necessary cookies or mobile SDKs (e.g., for login, performance, and security). If we later enable analytics or performance monitoring that is not strictly necessary, we will do so in compliance with applicable law and provide appropriate notices and choices.
11. User-Generated Content and Sensitive Information Notice
Content posted on the starry-sky page may be visible to other users. Please avoid posting sensitive personal information (e.g., government ID numbers, precise home addresses, health information). If you post such information by mistake, you may contact us to request deletion. We reserve the right to review, hide, or remove content in accordance with community rules and legal requirements.
12. Automated Decision-Making
We do not make decisions solely by automated processing that produce legal or similarly significant effects on you (e.g., credit approval or employment decisions).
13. Legal and Law-Enforcement Requests
Where required by law or necessary to protect user and public safety, we may disclose limited information in response to lawful requests. We review such requests for legality and scope and respond only when necessary and proportionate.
14. Changes to This Privacy Policy
We may update this Policy from time to time. The latest version will be posted on this page with the updated effective date. For material changes, we may notify you in the App or by other appropriate means.
15. Contact Us and Privacy Officer
If you have questions, requests, or complaints about this Privacy Policy, please contact:
Wilpuzzle Inc.
Email: support@wilpuzzle.com
Privacy Officer
Title: Privacy Officer
Contact: support@wilpuzzle.com
We will update this page if these details change.
16. Regional Addendum: California Notice at Collection (CPRA Summary)
For California residents, we disclose the following categories and purposes at collection (example summary):
Identifiers (email, display name, avatar, device identifiers): For account, features, and security.
Internet/Device Activity (crash and log data): For security and performance.
Commercial Information (subscription transaction records): For subscription and support (payments handled by Apple).
Sensitive Information: We do not collect government ID numbers, precise geolocation, biometric templates, or financial account credentials.
Retention: Based on what is necessary to achieve the purposes described; unverified email accounts are cleared after a defined retention period (see Section 4).
Sale/Sharing: We do not sell or share personal information.
California residents may exercise rights to access, delete, correct, and restrict use as applicable; we will respond within statutory timelines and may require identity verification.
Final Note
If you do not agree with this Privacy Policy, please stop using the App. Your continued use signifies that you have read, understood, and agreed to all terms herein.