Privacy Agreements

Effective date: 2025.11

Welcome to LuluLive.

This Privacy Policy ("the Policy") is formulated by [SELAMU TAMURU W] to regulate the handling of personal information and ensure compliance with applicable U.S. laws and regulations, including but not limited to the California Consumer Privacy Act (CCPA) and the minorren's Online Privacy Protection Act (COPPA)
 

1. Scope of privacy policy adaptation

This policy governs all interactions between you and [LuluLive (the "App")], including but not limited to using App services, email feedback, inquiries, etc. Your personal data controller is [SELAMU TAMURU (the "We"). This policy does not apply to third party services, and we do not share/sell any data with third parties. It should be noted that data collected by third parties is governed by their own privacy policies. If necessary, we recommend you review the privacy agreements and practices of third party services independently.

This policy applies to the following scenarios:

• You are using this application.
• You provide us with your personal information (data) in other ways for the purpose of communication.

You have the right not to provide us with personal information in the following scenarios:

• You are not allowed to provide it by law.
• You don't want to give it to us.
• You don't want us service providers to handle it.
• You're not satisfied with 18.

Please read this policy carefully. If you do not accept the contents of this policy, please remove or uninstall the application immediately. When you download and start using the application, we will consider that you have accepted the contents of this policy.
 

2. What does the privacy policy include?

LuluLive wants you to clearly understand what information we collect, use, share, retain, and transmit, as well as how we utilize and share this information. We also explain your rights and use plain language to help you easily grasp our data practices. We recommend you carefully read our Privacy Policy. This will help you use LuluLive in ways that best suit your needs.
 

3. What information will we collect?

In this policy, we list the types of information we collect. Please keep in mind that we collect:

• When you register for the application or modify your personal Settings, we will collect the data you provide, such as your user name, email address, phone number, profile picture, etc., and assign you an account with a unique identifier.
• When you purchase relevant services through the payment platform, we only collect transaction data from these platforms and will not collect or store sensitive information such as complete payment card number.
• We collect data about your use of the app, including messages, photos, videos, gifts and other user data. In addition, we process your conversations with other users and content you share during your use, which may be stored briefly to prevent violations.
• When you contact our customer service or report a problem, we will collect your contact information, message content and other relevant data, such as your name or alias, email address, IP address and any additional information you provide. This is mainly used to respond to and resolve the problems you have reported.
• When using the mobile phone used to use our products, we will collect the device model, operating system version, IP address, unique device identifier, time zone, system language, etc.
• When you perform the operation information in the product, we will collect data related to how you use the application, such as chat duration, interaction frequency, clicked content, and functions used.
• When you visit the application, we collect log data, including error reports, crash logs, etc., which are collected anonymously.

Important disclosures about third party SDKs

The application will be billed through third party SDKs such as Firebase, Tenjin, Kochava, Facebook, and Google Play. We automatically collect data at critical service nodes to conduct analysis, enabling us to optimize the product or enhance user experience. For further understanding, we strongly recommend reviewing the privacy policies and practices of these third party SDKs. Below are provided links to the respective SDK usage guidelines and privacy policies.

Important disclosure of sensitive personal data

The application will involve the following sensitive personal data, and we will describe in detail how it is used and processed.

Information under special protection

You may choose to provide information about your religious beliefs, sexual orientation, political views, state of health, race and ethnicity, philosophical beliefs or trade union membership. These and other types of information may be subject to special protection under the laws of your jurisdiction.

4. How we use your information

4.1 Manage accounts and provide services

We use your data to create and manage your account and provide you with basic features as follows:

• Account creation and login: Use your registration information (e.g., email address, phone number, etc.) to create an account and allow you to log in securely.
• Customer support: When you encounter a problem, our customer service team may review your account information to help resolve your questions or technical problems.
• Payment processing: If you use our paid services (such as buying gold coins for video calls), we will use your payment information to process the transaction and ensure that the payment is completed safely and smoothly.
• Internal operations: May store your chat history, friend list, to provide a continuous experience.

4.2 Establishing connections with users

In order to provide you with a stable, continuous and friendly social application experience. The specific use is as follows:

• Recommendations: We may recommend users who might be interested to you based on your interests, preferences and usage habits to improve the quality of interaction.
• Display user information: In order to help you find the right person to chat with, we will show your basic information (such as nickname, profile picture, gender, etc.) to other users, and we will also show them their information.
• Optimizing the communication experience: We may adjust the matching mechanism according to your usage data (such as chat duration, interaction frequency, etc.) to improve the accuracy of recommendations, so as to provide you with a friendly social experience.

4.3. Improve services and develop new functions

In order to continuously optimize and iterate our application, we usually analyze user data, obtain user needs, optimize existing functions and develop new functions, which is an essential part of our application. The specific usage is as follows:

• User behavior analysis: We will analyze users' usage habits (such as chat duration, matching success rate, etc.) to optimize the user experience, such as improving matching accuracy or improving chat interface.
• Test new features: We may test some users before launching new features to evaluate the effectiveness of new features and user feedback.
• Performance optimization: We collect device information, network connectivity, and other data to ensure that the application runs smoothly and reduces crashes or freezes.

4.4 Preventing fraud and illegal activities

In order to ensure user security, we use data to detect and prevent fraud, harassment, violations and other inappropriate behaviors. The specific uses are as follows:

• Investigate misconduct: If users report certain behaviors (such as harassment, fraud, etc.), we will analyze relevant chat records, transaction information, etc., to take appropriate measures, which is an important part of safeguarding your legal rights and interests.
• Detect abnormal activities: We may detect abnormal activities (such as batch creation of fake accounts, sending a large number of spam messages in a short time, etc.) from time to time and take corresponding security measures.
• Content to crack down on: If we detect content that violates our community guidelines, we may warn users, restrict their accounts, or even take legal action.

4.5 Comply with legal requirements

We provide services worldwide, so we need to comply with the laws and regulations of different countries and regions. The specific usage is as follows:

• Comply with regulatory requirements: When necessary, we process or store user data in accordance with relevant policies and laws and regulations in the user's location.
• Assisting law enforcement: If we receive a request from law enforcement in the user's location (such as an order from law enforcement), we may need to provide relevant user data to assist in investigations and the enforcement of laws.

5. How we share your information

• Your personal data will not be shared with any third party;
• Your personal data will not be transmitted directly from your application to another application on the device through the device.
• Except in the following cases:

• We may disclose your personal information in response to an investigation by law enforcement officials into suspected illegal conduct, as required by laws and regulations, court orders or local government agencies.
• If we merge, acquire or sell assets, your information may be transferred as part of the business transfer.
• We may integrate or select third party service providers to provide services for us or supplement our own capabilities/services. Despite our best efforts to investigate, there may still be a risk of capturing your personal information and causing data disclosure.

6.   How we keep your information

• We retain information if it is necessary to fulfill our products, legal obligations or protect the rights and interests of us or others. We will decide the length of time we need to retain information depending on the circumstances, and the following are the factors we consider:
• Whether we need this information to operate or provide the product. For example, we need to retain some of your information to maintain your account, display your personal information, and text chat history with friends.
• Information needs to be retained for legitimate purposes. For example, investigations may violate our terms or policies in order to prevent harm and enhance security and integrity.
• In the following cases, we will determine the retention period based on the circumstances:

• Legal claims or obligations
• Government investigation
• User complaints or regulatory (safety/inspection) procedures

Scenarios where the retention duration can be determined:

When you voluntarily cancel your account, your personal information will be retained for 7 days.

Please note that when we act as the controller of data, we will retain personal information in accordance with relevant policies, laws, regulations, and authorized purposes for data processing. The retention period shall not exceed the actual requirements of the original purpose. To determine the appropriate retention period, we consider factors such as the volume, nature, and sensitivity of personal information, potential risks of unauthorized use or disclosure, the purpose of data processing, and applicable policy and legal requirements. Should the storage purpose change, we will immediately delete the data.

At the same time, please note that chat records will be automatically deleted after the end of the conversation between both parties, unless temporarily stored due to security, violation inspection and other reasons.

7.   How we transmit your information

Why does the information get sent to other countries/regions?

As [LuluLive] operates globally and our users are located around the world, it is necessary for us to transmit information for a variety of reasons, mainly to meet the needs of the following scenarios:

• You share your information and interact with family or friends.
• Repair, analyze and improve our products.

Where will the information be stored?

Your information will be transmitted or transferred to, or stored and processed at:

• Our data centers are located in the United States, Singapore and other countries.
• You can use the countries/regions of [LuluLive].
• It may be transmitted to other countries/regions where the service provider is located.

How to ensure your information security?

We will conduct international data transfers in accordance with the following rules/conventions:

• We adopt the standard Contractual Clauses approved by the European Commission and other relevant departments;
• We use the same mechanisms as those provided for in the laws applicable to the transmission of data to the United States and other countries/regions.
• Applications employ in transit encryption to safeguard user data during collection or sharing processes involving data flows from end user devices to servers. For example, when providing video conferencing services, application providers implement various encryption protocols. The application will declare security policies in its security department. As long as they adhere to industry best practices by securely encrypting data during transmission between user devices and application servers, the data will be transmitted through secure connections.
• Applications use encryption technology to store and transmit sensitive information.
• Only authorized personnel can access your personal information.
• We collect and store your information only when necessary.

I hope to draw your attention to:

For your non sensitive information, such as your email address, IP address, etc., we cannot guarantee absolute security.

When you provide personal information or sensitive information to any third party during the use of the application, we believe that this is your right and does not fall within the scope of our protection.

8.   How do we respond to legal requirements, comply with applicable laws and prevent harm?

In necessary circumstances, we must provide information as required by law, which may result in the disclosure of your personal information;

There should be a law that says we need to have some reason to retain your information, and we need to comply with that law and retain your information.

In accordance with our product operating policies, we believe that retaining information will help prevent or deter bad behavior or activities in our products, and we will retain such information.

9.   Why and how we process your information

10.   GDPR and CCPA compliance

10.1, GDPR (General Data Protection Regulation)

If you are in the European Economic Area (EEA), you have the following rights under the General Data Protection Regulation (GDPR):

• Access: You may request a copy of your personal data held by us.
• Correction: You may request a correction of your personal data.
• Right to delete: You may request the deletion of your personal data (except in some cases).
• Restriction of processing: You may request that we restrict the processing of your personal data.
• Data portability: You may request us to provide data in readable format so that it can be transmitted to other service providers.
• Right to object: You may object to our processing of your personal data based on legitimate interests.

The above content applies to the European Economic Area. If users in this region need to exercise your "GDPR" rights, please contact us through the customer service email and feedback your rights needs.

10.2, CCPA (California Consumer Privacy Act)

If you are a resident of California, you have the following rights under the California Consumer Privacy Act (CCPA):

• Right to know: You have the right to ask us to disclose the categories and purposes of your personal information collected by us.
• Right to Deletion: You have the right to request us to delete your personal information. Please note that according to CCPA's regulations, when your deletion request involves legal obligations, security requirements, transaction records, platform operations, or backup data, we may not be able to immediately delete your personal information. We will truthfully inform you of the specific reasons and strive to meet your privacy requirements as much as possible.
• Right to refuse to sell personal Information: We will not sell your personal information, but you may still request that we not share certain data with third parties.
• Non discrimination: We will not discriminate against you for exercising your CCPA rights.

The above content is applicable to the California region of the United States. If users in this region need to exercise your CCPA rights, please contact us through the customer service email and report your rights needs.

11.   Minors's Privacy Protection

Dear users, we attach great importance to the privacy protection of minors. In accordance with the minors safety policy of the distribution platform, we refuse to provide services, data collection and marketing to users under the age of 18.

We attach great importance to the healthy growth of minors and hope to work with you to protect them. There are two ways for you to join us in this task:

(1) Complaints in "feedback" in the Settings of the application;

(2) Contact us through customer service email.

Our specific measures are as follows:

11.1 Data collection limitations

We do not intentionally collect, store or process any information about users under the age of 18, including but not limited to their names, addresses, emails, contact information, device identifiers, location data and any information that can identify individuals.

11.2 Illegal data processing

If we discover or are notified that a user under the age of 18 has provided personal information, we will take the following actions immediately, including but not limited to:

a. Immediately delete the relevant data and completely remove it from the server or database;

b. Block accounts related to products and individuals to prevent further access and use of the application;

c. Notify the user that his/her account has been closed and the data has been closed;

d. Refuse the user to further attempt registration and prevent the possibility that the user will continue to provide personal information.

11.3 Minor reporting mechanism

• If you discover a suspected underage user while using our product services, please keep relevant evidence (clearly identifiable content or proof) and contact us immediately through the customer service email or app complaint portal. We will complete verification and processing within 72 hours of receiving your email, and notify you via email of the resolution status.
• If you are a parent (guardian) and discover that your minor is using our product, please contact our customer service via the email address or complaint portal immediately. We will complete user verification and take appropriate actions within 24 hours of receiving your email or complaint ticket, then notify you via email of the resolution. We fully support guardians in removing or uninstalling this application themselves.

12.   Child safety standards

LuluLive, operated and managed by SELAMU TAMURU, is committed to providing a safe, healthy, and strictly regulated interactive environment for all users. This Child Safety Standards document is a publicly available policy document that clearly states our zero-tolerance stance on Child Sexual Abuse and Exploitation (CSAE) and ensures consistency with the Google Play Child Safety Standards Policy. This standard applies to all LuluLive users and the content they post.

12.1   Zero Tolerance CSAE Policy

LuluLive takes a strict stance against any form of CSAE behavior, including but not limited to:

·Creating, uploading, sharing, exchanging, or disseminating pornographic or sexually suggestive content involving children.

·Sexually enticing, deceiving, coercing, or manipulating minors. Soliciting, attempting to obtain, or exchanging nude photos, sensitive images, or personal information of children.

·Engaging in sexually suggestive communication, sexual role-playing, or other inappropriate interactions with children.

·Attempting to contact, entice, or guide minors to engage in inappropriate behavior.

·All violations will be handled in accordance with laws and regulations and may be reported to law enforcement agencies

12.2   Child Protection

12.2.1   Age Restriction

LuluLive is only available to adults aged 18 and above. The platform will implement age verification and immediately restrict or ban accounts suspected of being belonging to minors. 12.2.2 Content Review The platform combines automated monitoring with manual review to continuously monitor the following content:

·Real-time video

·Text chat · User-uploaded images and videos

·Any behavior that may involve minors

·High-risk or suspicious content will be immediately deleted, and escalated or reported as necessary.

12.2.2   Reporting Mechanism

Users can report content or behavior involving CSAE, suspected use of the platform by minors, and behavior that lures or exploits minors. Serious reports will be given priority and initial feedback will usually be given within 24 hours.

12.3   Prohibited Content and Conduct

·Inappropriate interactions with children (e.g., touching or caressing).

·Enticing children (e.g., befriending children online with the intention of having sexual contact with them online or offline and/or exchanging pornographic photos with them).

·Sexualizing minors (e.g., depicting, encouraging, or promoting images of child sexual abuse, or depicting children in a manner that could lead to sexual exploitation).

·Sexual blackmail (e.g., threatening or extorting children with real or claimed private photos of them).

·Child trafficking (e.g., advertising or enticing children for commercial sexual exploitation).

12.4   Enforcement Standards

To ensure platform security, LuluLive adopts the following enforcement standards for violations:

·Content Handling: Violating content will be deleted immediately.

·Account Management: Violating accounts will be suspended or permanently banned; device bans may be implemented if necessary.

·Legal Reporting: Actions involving CSAE will be promptly reported to law enforcement agencies.

·Further Measures: The platform reserves the right to take additional legal action against serious violators.

12.5 Developer Statement

SELAMU TAMURU is committed to continuously maintaining and publicly updating this standard to ensure that it strictly complies with Google Play's Child Safety Standards Policy and relevant laws and regulations on child protection in various countries, and to provide users with a legal, trustworthy and safe usage environment by continuously strengthening platform safety management measures.

13.   Your rights and choices

We respect your privacy very much. When you use our products, we provide you with a variety of options to manage your personal information and exercise your rights.

13.1 Access and correction of your personal information

• Access information: You can log in to your account at any time to view the personal information stored by us, including but not limited to user name, email address, profile picture, chat history, etc.
• Correction information: If your personal information changes that affect your normal use of the app, you can update the relevant information within the app or submit a correction request through the [customer service contact].
• Restrictions: Please note that in some circumstances (such as those involving security or legal compliance requirements), we may not be able to provide full access, but we will try our best to accommodate your request and provide a reasonable explanation.

13.2. Delete your personal information

• You have the right to request the deletion of your personal information, including but not limited to account data, chat history and payment information.
• In the Settings section, you can use the "Delete Account" feature to submit an account deletion request. We will process your request and delete your personal data within 7 business days.
• In some cases (such as for legal compliance, fraud investigation, account settlement, etc.), we may need to retain some information for a period of time. Once these reasons are no longer applicable, the data will be completely deleted.

13.3 Withdrawal of consent

13.3.1. Close some data permissions

Within your device or application, you can manage specific permissions to restrict our access to certain data. The following paths are generic and may vary to some extent from device to device.

• Location access: If you do not want the app to access your location information, you can turn off this permission by going to Device Settings> Privacy> Location Services. This may affect location based recommendations or matching features.
• Notification permissions: You can turn off push notifications in App Settings or Device Notification Management to avoid receiving app updates, message alerts, or marketing notifications.
• Microphone and Camera: If you do not want the app to access your microphone or camera (e.g., for video chat), you can disable permissions in Device Settings> Privacy> Camera/Microphone, but this may affect the use of video chat.

13.3.2. Cancel marketing messages

If you do not want to receive promotional, recommended or other marketing messages, you can unsubscribe by:

• Email: At the bottom of the marketing email, click the "Unsubscribe" link to stop receiving marketing emails.
• App notification: Go to app Settings-Notification preferences, select to disable promotional notifications, and keep necessary service notifications (such as payment reminders, account security notifications, etc.).

13.3.3 Request to stop specific data processing

You may ask us to stop processing some of your data, including:

• Match recommendations: If you do not want personalized matches based on your profile, preferences or interaction data, you can turn this feature off in App Settings-Privacy.
• Behavioral analysis: We may optimize the product experience based on your usage habits. If you do not want the app to analyze your usage behavior (such as access history, usage frequency, etc.), you can select "Limit Data Analysis" in Privacy Settings.
• Third party data sharing: Although we do not sell your personal information, if you wish to limit the sharing of data with certain third parties (such as advertising partners), you can manage it in Privacy Settings-Data Sharing, or contact customer service directly to submit a request.

13.3.4 Special Notes

• We will process your request as soon as possible and give feedback through email within 7 days.
• For data that cannot be deleted immediately (such as archived data for legal compliance requirements or fraud investigation), we will provide a reasonable explanation by email within 7 days.
• If you have any questions about your privacy rights, please feel free to contact us through customer service.

14.   Change and update

• This policy will not be updated at will unless Google Play policies and requirements, laws and regulations change, new features and services are launched, or business and technical adjustments are made.
• We may notify you of any updates through, but not limited to, in app notifications, email, announcements, etc.
• If you continue to use the app after being notified of the update, you agree with the new policy. If you do not agree with the new policy changes, you can adjust your data processing permissions on the privacy Settings page, contact customer service for other solutions, or deactivate or delete your account or app.

15.   Contact us

If you have any questions or requests about this policy, please contact us:

• Customer service email: mutegubotgu@gmail.com
• Complaint portal: Click the "Me" page of the application-click "feedback"-click send email (confirmed)

Thank you for using [LuluLive], we have been doing our best to protect your privacy!