LUA - PRIVACY POLICY

Last Updated: Feb 2024

This Privacy Policy (“Privacy Policy”), is an integral part of our Terms of Use  ("Terms"), and governs the collection, processing, usage and transfer of Personal Data by Lua Connect Ltd. (“LUA”, "we", “us” or “our”) in connection with: (i) visitors of our website available at: www.lua.earth; (ii) users accessing and using our LUA Platform and LUA Services (hereinafter defined as a “user” or “you”).

Any capitalized terms not defined herein shall have the meaning ascribed to them in the Terms. For the purpose of this Privacy Policy, our website, the LUA Platform and the LUA Service will be collectively referred to as the "LUA Services". 

This Privacy Policy further explains how you can exercise your rights related to your Personal Data, in accordance with applicable laws and regulations.

If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Policy, please email us at: support@lua.earth.

TABLE OF CONTENTS: 

• The Data We Collect & Purpose of Use

• Cookies & Tracking Technologies

• Data Sharing - Categories of Recipients We Share Personal Data With  

• Retention And Security of Data 

• Data Transfer

• User Rights

• Persons Under 18

• Amendment to This Privacy Policy

• Contact Us

THE DATA WE COLLECT & PURPOSE OF USE

Types of Data Processed by LUA

If you register to our LUA Platform or use our LUA Services, LUA collects two types of data:

"Non-Personal Data" - meaning, information which does not identify a specific individual and cannot reasonably be used for such identification, and for example anonymized and aggregated data. We collect Non-Personal Data regarding use of the LUA Services, such as the scope, frequency, latency, pages accessed and viewed, time and date you have accessed the LUA Services, language preference, and other technical information regarding the device used to access the LUA Services, for example type of device, type of browser, operating system, etc. 

Non-Personal Data is used mainly in order to maintain and develop our LUA Services, including among others, in order to measure and understand the level of engagement with the LUA Services, for general business analytics for ensuring the technical functioning of our network, to help prevent fraudulent use of the LUA Services and for developing new LUA Services and features.

“Personal Data" - meaning, information which identifies or can be reasonably used to identify an individual, and for example your name, phone number, email address, pictures, unique online identifiers, etc. 

Personal Data Processed by LUA  

The types of Personal Data collected by LUA through your access and use of the LUA Services are listed in the table below, as well as the purpose of use. Note that, some types of Personal Data are required for your use of all LUA Services (for example, for registration), some types may be required solely for certain features, and some are optional. 

Type of Personal Data

Purposes of Collection & Use by LUA

Contact Information

When you access and register to our LUA Services, you will be initially requested to provide your mobile number and your email address. 

Verification and Authentication

We will use your mobile number and email address to authenticate and verify your identity, as well as to make sure you do not already have a LUA Account, including sending you a verification code once you sign up. We will further use your contact information for customer support purposes, for example to identify you and locate your LUA Account if you contact us with any inquiry. 

Operational and Marketing Messages

Your email address and/or mobile number will be further used to send you operational and promotional messages related to the LUA Services. You may unsubscribe from our marketing mailing list at any time. Please note that even after you have chosen to unsubscribe, we may send you service-related messages, including administrative messages that relate to your use of the LUA Services. 

LUA Profile Information

Through the registration process, you will be requested to provide your personal details, including your name, date of birth, gender, photos, etc., as well as information related to your personal characteristics such as your interests, spoken language, gender identity, relationship status and preferences, etc. 

Creation and Administration of Your LUA Account & LUA Profile

We will use your LUA Profile Information in order to create and customize your LUA Profile, as well as display the information to other users as part of your LUA Profile.

Providing & Delivering the LUA Services 

We will further use your LUA Profile Information to operate, provide and deliver our LUA Services. This includes offering you to connect with other users that might match your personal characteristics and preferences according to the LUA Profile Information you have provided, as well as offering other users to connect with you according to such information. 

Improving and Customizing the LUA Service & Analytics

We will use your LUA Profile Information for statistical analysis of the usage and functionality of our LUA Services, product development, continued improvement of existing features and developing new features. The information will be used for this purpose in an aggregated manner. We may further use it to customize content we show you, including our customized offers of certain services. 

User Generated Content 

As part of your use of the LUA Services, we will store the content you upload, send, create, share or otherwise disclose on LUA Platform, including, without limitation, pictures and images, text and voice, messages, videos and other materials, both publicly and privately (through messaging features). 

Providing & Delivering the LUA Services

We will use your User Generated Content to operate, provide and deliver our LUA Services. This includes enabling you to post and share your User Generated Content with other users or communities, and generally utilize our content features.

Note that, with regards to private messaging, it will be stored as part of the App however, we will access private messaging only in the rare circumstance that we receive an abuse report on behalf of another user, claiming you have breached our Terms and community guidelines, and only in order to investigate such claim. 

Online Identifiers and Activity Data

When you access and use the LUA Services, we collect online identifiers such as IP address and UDID, as well as advertising identifiers associated with your device (subject to your permissions through the App). 

Online Identifiers might be collected by us, shared by third party advertising partners or collected through our use of third party's tracking technologies such as cookies, as detailed below. 

In addition, we may collect your online activity data, associated with your Online Identifiers or LUA Account, and for example, pages viewed the pages that directed you to our website, information related to errors and crash reports, data regarding your usage of our LUA Services, such other users you have interacted with, requested to interact with or offered by us to be connected. 

Verification and Authentication

We will further use Online Identifiers for authentication purposes, usually within log files upon your registration and access. 

Improving and Customizing the LUA Service & Analytics

We will use Online Identifiers and online activity data for statistical analysis of the usage and functionality of our LUA Services, product development, continued improvement of existing features and developing new features as well as detect and fix errors. The information will be used for this purpose in an aggregated manner. 

We may further use it to customize content we show you, including our customized offers of certain services.

In addition, we may use online activity data associated with your LUA Account regarding other users you have interacted with in order to offer you to connect with users with similar characteristics as well as try to avoid offering you to connect with users you have already rejected. 

Advertising our LUA Services

We may advertise our LUA Services on third party platforms, and as part of such operation, we may receive information, associated with your Online Identifiers, related to our advertising campaigns, and for example, regarding which advertising campaign led you to join our LUA Service, for the purpose of assessing such campaigns performance. In addition, such data might be collected through our use of third party's cookies and tracking technologies in order to advertise our LUA Services on other platforms. 

Location Data

When you register to our LUA Services, you will be further requested to provide an approximate geographical location or precise geographical location (meaning – GPS location, subject to the permission you will provide through the App).  Approximate location might also be extracted from your IP address. 

Verification and Authentication

We will use your Location Data for verification and authentication purposes.  

Providing & Delivering the LUA Services

We will use your Location Data in order to provide our LUA Services which are location based – for example, to offer you to connect with other users in the area of your location. 

Marketing Messages and Offers & Advertising

Your Location Data might be used in order to send you location-based offers and marketing communications (including, for example, push notifications). Approximate location, extracted from your IP address might be further used for customized advertising purposes. 

Improving the LUA Service & Analytics

We will use Location Data for statistical analysis of the usage and functionality of our LUA Services, product development, and continued improvement of existing features. 

Data Provided When You Voluntarily Contact Us

If you voluntarily contact us, for example, sending us an email, filling out online "contact us" forms or otherwise contacting our customer support with any inquiry, you will be requested to provide certain information such as your name, email address, phone number, etc. In addition, Personal Data might be included in the content of your inquiry. 

Responding Your Inquiries

We process this data in order to respond to your inquiry and provide you with the requested information and support and communicate with you. 

Improving our LUA Services

We may further use such data for the purpose of improving our LUA Services and customer support (for example in order to train our customer support team, as well as internal management operations).

Newsletter Registration 

If you voluntarily choose to subscribe to our newsletter and marketing list, you will be requested to provide certain information such as your name and email address. 

Marketing Messages and Offers & Advertising

We will use the information you will provide solely in order to send you the content you have signed up to receive. You may unsubscribe at any time, as shall be detailed in the marketing messages you will receive from us (e.g., using a designated link or by sending us an email). 

All types of Personal Data collected and stored by LUA, as set forth above, might be used for: 

• LUA's compliance with its legal obligations; 

• Security, fraud detection & enforce LUA's Terms;

• for the purpose of protecting your or third party’s life safety and security as well as humanitarian purposes 

LUA's compliance with its legal obligations

Certain types of Personal Data will be used and further stored where it is required for us in order to comply with our legal obligations, including, where required in order to comply with any law enforcement bodies such as binding order. 

Security, fraud detection & enforce LUA's Terms

All types of Personal Data collected by LUA might be further used to protect and secure our LUA Services and enforce our policies.

For example, Online Identifiers can be automatically monitored in order to prevent malicious attacks and fraud. 

We may further use electronic activity data and User Generated Content in order to track, investigate, log and block users that infringed our Terms and policies or reported by other users. 

Protecting your or third party's life safety and security

We may further process Personal Data in very limited circumstances, where it is necessary for the purpose of protecting your or third party's life safety and security as well as humanitarian purposes.

COOKIES & TRACKING TECHNOLOGIES 

We use cookies and other similar tracking technologies or methods of web and mobile analysis to gather, store, and track certain information related to your activity and interaction with the LUA Services.   

A “cookie” is a small piece of information that a website assigns to your device while you access some websites. Cookies are very helpful and may be used for a variety of different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker, easier and smoother. Cookies are also used to help customize your experience and for advertising purposes (including personalized advertising). You can find out more information about cookies at www.allaboutcookies.org.

In general, there are several types of cookies and tracking technologies that may be used on our website or in App, including the following: 

• Essential Functionality, Operation & Security Cookies. These cookies and tracking technologies are essential for enabling user movement around the website, and the App, as applicable, to function properly, and for security purposes (i.e., used to authenticate users, prevent fraudulent use, and protect user data from unauthorized parties). This category of cookies and tracking technologies either cannot be disabled, or if disabled, certain features of the website or App may not work. 

• Analytical, Measurement & Performance Cookies. These cookies and tracking technologies are used to collect information about how our website and App are being used, in order to improve our LUA Services and the way we offer them, as well assess performance of the content and the way it is displayed on our LUA Services. These cookies and tracking technologies enable us, for example, to assess the number of users who have viewed a certain page as well as their country of origin. 

• Targeting & Advertising Cookies. These cookies are set by our third-party service providers and business partners. They may be to build a profile of your interests and show you personalized content and advertisements. They work by uniquely identifying your browser and device. 

The third parties’ cookies and tracking technologies used in our website and App are as follows: 

Provider 

Purpose

Privacy Policy and Opt-Out

Google Analytics

Analytics, Measurement & Advertising

For privacy information, go to: 

http://www.google.com/intl/en/policies/privacy/ 

To opt-out install the plug-in:  

https://tools.google.com/dlpage/gaoptout  

For additional information regarding our use of Google products, visit: https://policies.google.com/technologies/partner-sites

Facebook 

Functionality &
Advertising 

https://www.facebook.com/policies/cookies/ 

Sharethis 

Analytical, Measurement & Performance

https://sharethis.com/privacy/ 

Hotjar

Functionality & Operation 

https://www.hotjar.com/legal/policies/privacy/ 

https://help.hotjar.com/hc/en-us/articles/115011789248-Hotjar-Cookie-Informatio 

AppsFlyer

Analytics and Attribution

https://www.appsflyer.com/legal/services-privacy-policy/

MixPanel

Product Analytics

https://mixpanel.com/legal/privacy-policy/

Opt-Out:

You can change your cookies settings at any time to control cookies placement by changing your browser’s privacy preferences (please visit the help pages of your web browser). Please note, however, that if you disable cookies or refuse to accept them, you might not be able to use all of the features we offer or some of the features may not function properly. You may not be able to store your preferences and some of our pages might not display properly. We may, at our sole discretion, delete old cookies after a certain time in which no activity has occurred from a user.

In addition, you may disable collection of Personal Data through certain tracking technologies implemented in the App (e.g., analytics) through the settings of your mobile device.  

Your web browser allows you to manage the cookies and your choices. The configuration for each browser is different. You may find more information about managing cookies on different web browsers below:

Browser

Relevant Link

Google Chrome

https://support.google.com/chrome/answer/95647?hl=en;

Firefox

https://support.mozilla.org/en-US/kb/block-websites-storing-cookies-site-data-firefox

Opera

https://help.opera.com/en/latest/security-and-privacy/;

Internet Explorer

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;

Safari

https://support.apple.com/en-il/guide/safari/sfri11471/mac

Edge

https://support.microsoft.com/en-us/help/4027947/windows-delete-cookies

DATA SHARING — CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH  

LUA will share Personal Data with third parties, mainly for the purpose of the operation of the LUA Services, as well as to improve, protect and advertise the LUA Services. The circumstances, in which LUA will share your Personal Data, as well as the categories of such third-party recipients, are as follows: 

• LUA's affiliated companies — we will share Personal Data with our affiliated companies such as subsidiaries, sister-companies and parent companies, mainly, for the purpose of LUA Services' operation. 

• LUA's Service Providers — we will share Personal Data with our service providers that perform business operations on our behalf, including, for example, data storage providers, customer support providers, and data security providers. When we do so, we ensure that the service providers only have access to such information that is strictly necessary in order for us to provide the LUA Services. 

• Legal and Law Enforcement — we may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations, or alleged illegal activity, or any other activity that may expose LUA or its users to legal liability, and solely to the extent necessary to comply with such purpose.

• Corporate Transactions — we may share certain data in the event of a corporate transaction (for example, sale of a substantial part of our business or asset, merger etc.) with our acquiring company. In such an event, we will require the acquiring company to assume the rights and obligations described in this Privacy Policy.

• Other LUA Services' users — we may share your Personal Data with other LUA users, for example, when you request us as part of the LUA Services to disclose your photo. In addition, your Personal Data, for example LUA Profile Information, will be disclosed to other users, according to your preferences (i.e., private or public).  

RETENTION AND SECURITY OF DATA

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you will express your preference to opt-out, where applicable. 

The criteria used by us to determine our retention periods are as follows: 

• We retain Personal Data for the periods needed in order to achieve the purpose for which Personal Data was collected. For example, Personal Data required to be retained in order to maintain your LUA Account and to enable you to use the LUA Services (for example, your mobile number and email address), as well as your LUA Profile Information that will be retained for as long as you maintain your LUA Account. 

Note that, upon deletion of your LUA Account, your LUA Profile Information and User Generated Content will be deleted from our systems, excluding chat content and photos which we will keep on our systems for security purposes.

• We further retain Personal Data for the periods needed in order to comply with our obligations under applicable laws. In addition, in case of a dispute, we may retain certain types of Personal Data as necessary and applicable to the claims, until such dispute is resolved. 

• We may at our sole discretion, rectify or erase information from our systems, without prior notice to you, once we deem it is no longer necessary for such purposes, or when we believe such information might be in breach of our Terms. 

We implement physical, technical, and administrative security measures intended to prevent your information from being accessed or used without authorization, destructed, or accidentally lost. However, please note that the transmission of information via the internet can never be fully secured and we cannot guarantee your information will never be unlawfully accessed or used. 

DATA TRANSFER

We operate globally and thus, your Personal Data might be stored outside your jurisdiction, including within cloud services in the US or EU. We take appropriate measures to ensure that Personal Data receives an adequate level of protection in transfer.  

USER RIGHTS 

Depending on your jurisdiction, data protection and privacy laws provide you with the ability to exercise certain rights regarding your Personal Data that we process. 

Where provided under applicable law, you may have the right to ask us to delete Personal Information, subject to applicable exceptions, such as in order to preserve that information for anticipated litigation or demands from a regulator. In addition, you have the right to know which Personal Data we are collecting, as well as to request us to correct any Personal Data you believe is not updated. You may have the right to obtain a copy of your Personal Data, the right to object to our processing of your Personal Data, the right to restriction of the processing, and the right to withdraw your consent.

To assert any of these rights, please contact us at: support@lua.earth. Note that we may request proof of identity before we provide you with any information. 

In addition, you have the right to lodge a complaint with a supervisory authority, subject to applicable law.

Note that, you may exercise some of your rights independently through your LUA Account, for example, delete your photos and User Generated Content, review and revise or change your Personal Data on your LUA Profile, etc.

PERSONS UNDER 18

Our LUA Services are restricted to individuals who are 18 years of age or older. We will immediately discard any information that we receive from a user that is considered a "child" upon our discovery that such a user shared information with us. Please contact us at: support@lua.earth, or as described below if you have reason to believe that a child has shared any information with us. 

AMENDMENTS OF THIS PRIVACY POLICY

We reserve the right to amend this Privacy Policy at any time. As such we recommend that you re-visit this page frequently and review the Privacy Policy for any changes that we may have made. In the event that we made any substantial changes to this Privacy Policy, we will make reasonable efforts to provide you with notification with respect to such changes, if we are required to do so by applicable law. The changes to this Privacy Policy will go into effect as of the date listed in the “Last Updated” heading located at the top of this Privacy Policy.

CONTACT US

If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at:

• Lua Connect Ltd. - 516452455
  Vinkler Alter 12, Petah-Tikva,
  Israel
  4972132

• by email: support@lua.earth

• or through the App.