Most recent update: June 28, 2020
1. DATA WE COLLECT
We may collect and store information about you in connection with your use of the Service, including any information you transmit to or through the Service. We use that information to provide the Service’s functionality, fulfill your requests, improve the Service’s quality, engage in research and analysis relating to the Service, personalize your experience, track usage of the Service, provide feedback to Business Services users, display relevant advertising, market the Service, provide customer support, message you, back up our systems, allow for disaster recovery, enhance the security of the Service, and comply with legal obligations. Even when we do not retain such information, it still must be transmitted to our U.S. – based servers initially and stored long enough to process.
a. Account Information: If you create a Lula account, we may store and use the information you provide during that process, such as your full name, user name, email address, phone number, date of birth, and other information you may provide such as your gender, profile picture, device location and contacts. We may publicly display your name, geographic area, friends list, as well as any photo or other content you submit through the registration process, as part of your account profile. You can modify some of the information associated with your account through your account settings.
b. Data Collected While Using the Service: If you opt-in, we automatically receive Data about your location (latitude and longitude) and IP address whenever you interact with, or use, the Service (e.g. open the app). We use various technologies to determine your location, such as the location services of your operating system or browser, sensor data from your device (e.g. magnetometer or barometer, Bluetooth data, beacon data, Wi-Fi access points, GPS data, and cell tower data), and other Data that may help us to understand your precise location. We may also collect additional Data about you when you use the Service. For example, we receive Data:
Relating to how you interact with the Service, such as your search terms, what pages you view, your access times, the time you spend on each page, your IP address, the redirected pages, any messages, search history keystrokes, or other original content you post to the Service, and any photos you post to the Service;
Relating to your device, such as your hardware model, operating system, unique ID, browser type, language, and wireless network;
Collected by technologies that measure your engagement as you use the Service.
If you use our app and have enabled background location services in our app, you have permitted us to access location information about you even when you do not have the app open (as permitted by your device settings). We will continuously collect device location information to provide you with a better user experience, to verify your location when using the app, and potentially prompt you to interact with the app or serve you a relevant advertisement. You may turn off background location services at any time by going to your device settings and toggling off background location.
c. Data Received From Third Parties: We may receive Data about you from third parties, including those that provide services to us or that interact with the Service. This Data may include Data received from operating systems such as settings, operating system version, device models, carriers, location information, IP address, or mobile device identifiers. If you created your account using your Google, Twitter or Facebook account profile, we may receive certain information from these companies, such as your first name, last name, gender, birthday, email address and your Google, Twitter or Facebook ID, which we will use for the purposes of constructing your Lula user account and to sign you in to Lula.
d. Contacts: You can invite others to join or become your friend on Lula by providing us with their contact information, or by allowing us to access your contacts from your mobile device or third-party sites such as Facebook, Twitter, or Google, to select which individuals you want to invite. If you allow us to access your contacts, we will encrypt and transmit that information to our servers, storing information from users you choose to invite to the Service, but only keeping other information long enough to process your invitations.
2. HOW DATA IS USED
a. To Operate, Maintain and Improve the Service: We may use your Data to operate and maintain the Service and to understand you better and tailor the Services to you. For example, we may use device signals to determine that a particular device is within a particular venue.
We may also use your Data for internal research and development, to improve the Service, to offer new products, features and tools, or to suggest that you friend another user, but only to the extent that this is in compliance with applicable law. We use your Data for all of the listed purposes through inferring your interests and preferences, looking at your search history or allowing you to find and add friends who are also using the app by reviewing your device’s contact list or if applicable, your Facebook, Google or Twitter account if you have opted to connect these accounts to your Lula account. In these situations, we do not store your contact lists for more than a temporary period of time.
Additionally, if you consent to sharing crash data (should the app crash) with us, we may use that data to help us analyze the cause of the crash.
b. Communicate With You: We may use your Data to communicate with you, including by email, text (only if you opt-in), or in our app, about new product offerings, updates to the Services, or anything else we think may be of interest to you. You can opt-out of receiving i) push notifications by adjusting your device settings and ii) emails by clicking the unsubscribe link in the footer of our messages.
c. Business Services: We may provide your i) publicly posted content and ii) Data otherwise collected by us, delivered in non-personally identifiable form, to our customers of Business Services, in order to deliver those Business Services, including anonymized analytics. We may also use your Data to target and send personalized deals, messaging, or advertising to you.
3. HOW DATA IS SHARED
a. Public Content: Your contributions to the Service are intended for public consumption and are therefore viewable by the public, including your photos, ratings, and reviews. Your account profile (e.g., name, location, profile photos and friends) is also intended for public consumption, as is some of your other activity through the Service, like how you rate businesses, where you check-in or where your friends check-in on your behalf, which contributions or users you follow, and which businesses you bookmark. You can limit the public nature of some of these activities through your account settings.
b. Data That May Be Shared With Third Party Partners And Service Providers: Data will be shared with affiliates that enable the app to function (e.g. hosting platforms, email programs, and other essential services) and we may also share information only in aggregate form with a Business Services customer. If you use a third party login service such as Facebook, Twitter, or Google, we will share basic profile information, including your username, email, and phone number. If you wish for us to refrain from sharing information from these providers, please do not use these login features.
No PII will be shared with third parties, and Lula will not sell PII to anyone. Additionally, continuous location information that may be collected will not be sold or shared with anyone, regardless of whether it has been anonymized.
4. DATA RETENTION AND ACCOUNT TERMINATION
When we collect Data, we may retain it indefinitely. However, when you close your account with us, we will remove PII provided and dissociate public posts and previously purchased items from your account profile, but we may retain information provided to the app, such as previously purchased items, for the purpose of maintaining the purpose and functionality of the Service. We may also retain information to prevent, investigate, or identify possible wrongdoing in connection with the Service or to comply with legal obligations.
You may close your Lula account within the app by navigating to Settings – Account – Delete Account. After deleting your account, a Lula representative may reach out to you via email to solicit feedback about your experience with the Service.
The Service is intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information without parental consent, please contact us at firstname.lastname@example.org. If we become aware that a child under 13 has provided us with personal information without parental consent, we will take steps to remove such information and terminate the child's account.