PRIVACY POLICY

Update time: Ot=October 31, 2023

The “Lugo” Welcome To You!

This is the Privacy Policy of Lugo App (“Lugo”, “us”, “we”, "Service" or “our”) . In this Privacy Policy, we refer to our products and services as the “Service.” Please read on to learn more about our data handling practices. We respect your privacy and want you to understand how we collect, use, and share data about you. This Privacy Policy covers our data collection practices and describes your rights to access, correct, or restrict our use of your personal data; in plain language, keeping legal and technical jargon to a minimum. Your privacy is at the core of the way we design and build our Services and products you know and love so that you can fully trust them and focus on building meaningful connections. Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use the Service. Your use of the Service signifies that you agree with the terms of this Privacy Policy.

Please read this Privacy Policy carefully.

Age

The Service is not directed at children under the age of eighteen (18), and we do not knowingly collect personally identifiable information from children under the age of eighteen as part of the Service. If we become aware that, as part of our services, we have inadvertently received or collected personally identifiable information from users under the age of 18, we will delete such information from our records. If you are under the age of eighteen, please do not use the Service.

Information we collect

When we refer to "personal information" in this Privacy Policy, we mean information about an identifiable individual. Collect the following personal information in connection with our services:

Information that you provide to us directly or that we receive from third parties

We may collect information directly from you or from other companies with whom you contact.

● When you create an account and register for our services, you will provide us with your mobile phone number, email, date of birth, gender, nickname and other information. We may also collect other information that you provide to us if you register and log in with your Facebook, Apple or Google account. For example, if you register with a Facebook account, we may collect and store your Facebook ID and corresponding token on our servers, and if you expressly agree, we will be able to access and collect certain information you provide on Facebook (for example, your first and last name, email address, profile picture, friends list and birthday).

● When you start using the service, we will collect user-generated content that you choose to share, send and/or upload on our service, including but not limited to comments, text messages, photos (including captured images), etc., as detailed below :

1) Device information: your device OS platform, device information including device type, tag, OS model and version, IP address, device language, device time zone, application version you are using, locale country and device language, location (country and city) where you are logged in, available languages, device capabilities, band width, network type, - and traffic to and from our website, error report information, time the error occurred, features used and the state of the Application when the error occurred.

1) Log information: Usage information, such as, URL, redirect URL, execution time, network type, network info, cookies, access and history reports.

2) Read installed applications: When you use our service, if you want to share your favorite content with third-party applications, we need to determine whether third-party applications are installed to provide you with the correct sharing function.

3) Read clipboard: When you share or receive sharing information, we need to access your clipboard locally to realize the display function. We only recognize local clipboard content, and will not upload any other information from your clipboard to our servers.ther information of your clipboard to our server.

4) Location information: We will process your location or geographic information based on your consent or where permitted, where this is necessary to provide the Services you have requested.

5) User Content such as photos, screenshots, comments and other material you create on the Services may also be collected. Your photos and videos may be captured by other users on the Services, which may be stored and used by us or third-party services for content moderation and community safety monitoring purposes.

6) Service usage information: Details of your interactions with other users including following or following history, details of interactions between you and the service or you and our website including history of reports.

How we use the information

Our provision of services is based on your contractual relationship with us

1) We process your personal information when this is required under our contract with you, to:

● Providing you with our services, and the specific features you choose when using our services, which may require personalizing the content of our services;

● Give you augmented reality or beautiful features via Apple's TrueDepth API. Such information may also be used to improve the features provided by our Service (such as photos, videos, effects, avatars and more), especially to provide users with more suitable content and to apply avatar functions, makeup, filters in suitable positions. We will not use this information to personally identify any user. This information is processed in real time to provide and fix these features only, and is discarded when use of the feature is complete. We do not share this information with third parties, do not store it on our servers, or process it for any purpose other than the Service functions mentioned above;

● Identification and authentication of you so that you can use our Services and to prevent illegal or non-compliant use of the Services;

● Reducing the collection of personal information by children under a certain age as defined in this Privacy Policy;

● Provide you with all administrative notices, warnings and communications relating to your use of the Service;

● Effectively managing our relationship with our customers, including by communicating with you, answering and dealing with inquiries and reports, resolving technical issues, providing you with considerate customer support and sending you necessary information relating to our Services

2) Use of information for further purposes:

● To improve the Service, and to develop and offer new services. We may use your information to improve performance or develop new services.

● To provide information about events and opportunities to participate in events, to provide advertising information;

● To contact you via email, SMS, application press notification or otherwise to notify you about new products, services or promotions offered by the Company (You can opt out of these emails or SMS by sending an email to JaeFixz@gmail.com

● To collect statistics about Service usage including history of Service usage, frequency of access and interactions between users, to analyze customer behavior, build customer usage patterns and profiles to identify regional and global user trends and optimize our offer to customers globally and to improve the Service and the environment uses statistics;

● To protect, identify, monitor and prevent fraud and other criminal activity, other activity that may violate our Terms of Service or other applicable laws, or lead to other claims or liability.

● To limit unlawful use of the Service and our Terms of Service, to prevent use of the Service that interferes with the operation of the Service, including fraudulent use, and to prevent account theft.

3) Other

● Conform and enforce necessity under applicable law, relevant industry standards and our policies, including this privacy policy.

● Execute court orders and subpoenas, and respond to legally binding requests from governments, government agencies, public authorities and/or regulators.

● Protect our legal rights, including by handling complaints, obtaining legal advice and establishing, exercising or defending legal claims relating to us or any other group company and our Services.

How to delete your information and data

You can choose to delete data at any time. If you ask us to delete your account, we will use commercially reasonable efforts to delete your data from our servers, subject to any applicable legal or other requirements to retain certain records of your personally identifiable data. Please note that deletion of your personally identifiable data from our databases may result in our inability to provide services to you. If you need to delete any data or personal information we may have, you can email us at JaeFixz@gmail.com, however, we may ask you to verify your identity or provide other information before we allow you to delete personal information information.

Information Section

We transfer or disclose your personal information to third parties as highlighted below:

● We share your information with our personnel, including contractors and agents, and other companies, so that this is necessary to provide our services and to fulfill the purposes set out in Section 2 above.

● Service providers: We also transfer or disclose your information to carefully selected companies that provide services on our behalf; for example companies that help us develop and operate systems for our services, payment and reimbursement of services, IT service providers, security, hosting, analytics, email, billing or marketing services. These entities are only permitted to access and use your personal information so this is necessary for them to provide us with their services and they are not permitted to use this information for any other purpose.

● Business advisors: We may share, for example, your information with our attorneys, accountants, business consultants, insurers and auditors, so that it is necessary for them to provide us with their services.

● Government authorities, courts, regulators or other third parties where appropriate: we will disclose personal information to government authorities, courts, regulators or other third parties where we have the legal precedent to do so or where we believe it is necessary :

● to comply with the law or respond to mandatory legal process (such as search warrants, statute or court orders);

● to confirm or enforce agreement to the terms and policies that govern our Services and to investigate fraud or other unauthorized activity related to the use of our Services or affecting our business, so that explanation is permitted by applicable data protection laws;

● to protect and defend the rights, property, and safety or security of our business operations and that of our affiliates, staff, business partners, our customers or members of the public.

● Other troops with your consent or your request. In addition to the explanations stated in this Privacy Policy.

Any information or content that you provide voluntarily to post on the Service ("User Content") may become available to the public. Once you have shared User Content or made it public, that User Content may be re-shared by others. This Privacy Policy does not apply to such public information.

Protection of Personal Information

We take appropriate steps to ensure that we process and store information in accordance with the following principles:

● at least for the time that the information is used to provide you with our services;

● as required by law, contract or regarding our legal obligations (eg tax laws);

● only as long as necessary for the purposes for which it was collected, processed, or longer if required under any contract, by applicable law, or, in an anonymous form, for statistical purposes, with appropriate safeguards. For example, if there is an argument between you and the Company or you fail to pay for our services, we may retain relevant information until the dispute is resolved or until payment is made, respectively.

● Where we process your information with your consent, we process the data until you ask us to stop and for a short period after this (to enable us to implement your request). We also keep a record of your request to honor them in the future.

Your choice

Where permitted we may contact you via email, phone call, text message or push notification via our mobile application. To submit a request regarding receiving such communications from us, please contact us using the information set out in the "Contact us" section below.

You can opt-out of our marketing communications at any time by contacting us directly (see the "Contact us" section below). As noted in the Your rights section below, you have the right to object to using personal data for direct marketing purposes at any time.

Please note that if you do not opt-in from our marketing communications, we will still send service messages to provide you with necessary information relating to your contract and the services you use (for example, to update changes to our Terms of Use).

Your rights

To the maximum extent provided by applicable law, you may request access to your personal information, or correct or update any outdated or incorrect personal information we hold about you. You may also have the right to request that we delete personal information we hold about you. You can access and update some of your information through your account settings. You are responsible for keeping your personal information up-to-date.

So provided by applicable law, you can also ask us to limit or restrict processing of your personal information, as well as to provide you with personal information that we collect from you so that you can use it for your own purposes, and to ask us to share (port) this data to other controllers.

In addition, to the extent provided by applicable law, you may object to processing your personal data in some circumstances (notably, where we do not need to process the data to comply with contractual or other legal requirements).

You may also have the right under applicable law to object at any time to using your personal information for direct marketing purposes, including direct marketing-related profiles.

However, these rights may be limited, for example if fulfilling your request would reveal personal data about other people, where they would violate the rights of third parties (including ours) or if you ask us to delete information that we are required by law to save or have a compelling legitimate interest in keeping. We will notify you of any relevant exceptions we expect when responding to any request you make. To make a request regarding your rights or to make an inquiry, use the contact details under the "Contact Us" section below.

How we protect personal information

We take the protection of your information seriously and we have safeguards designed to protect the information we collect through our Services. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is truly secure.

Please note, however, that the Service allows you to share text messages, photos, screenshots, videos and other communications on the Service with other users, and if you choose to share these items with other users of the Service, we may not be able to delete them from our servers. or make it unavailable to anyone you share them with. Sending and sharing text messages, photos, screenshots, videos or other communications on the Service is your decision. By choosing to share that information, you should understand that you may no longer be able to control how that information is used and that it may become publicly available (depending in part on your actions or the actions of others with whom you have shared the information). The service is not responsible for any use or misuse of the information you share.

Children's personal information

The Service is not directed to children under 18 and we do not knowingly solicit or collect personally identifiable information from children under 18 as part of the Service. In addition, we do not knowingly sell personal information to children under 18 years of age. If we become aware that we have inadvertently received personally identifiable information from a user under 18 as part of the Services, we will immediately delete that information from our records. If you believe that a child under 18 may have provided us with personal information, please contact us using the information set out in the "Contact us" section below.

Contact Us

For more information about our privacy practices, or to exercise any rights you may have under applicable law, please contact us at JaeFixz@gmail.com

Updates to Our Privacy Policy

We reserve the right to make changes to this Privacy Policy from time to time. We will let you know before we make any changes to this Privacy Policy. You agree to receive electronic communications and/or posting of the amended Privacy Policy on the Service, and you agree that such electronic communication or posting constitutes a notice to you of the Privacy Policy.

If we make material changes to this policy, we will notify you by posting the modified Privacy Policy. You agree that your continued use of the Service after we publish the amended Privacy policy constitutes your acceptance of the amended Privacy policy. If you do not agree to the terms of the Privacy Policy, you may not use the Services at any time.

All of Third party sdk that we used

● image_editor_common : image processing library for saving/uploading/previewing images. 

● image_cropper : Image processing library for image cropping.

● just_audio: audio playback library, used to play music in the live room.

● glide: image loading library, used to display images.

● flutter_image_compress : Image compression library, used to compress image files.

● image_picker : library for selecting images from albums and acquiring images by taking pictures.

● path_provider_android : in-app file handling library for reading and writing cached files

● wakelock : A library to prevent the screen from closing automatically, used to prevent the screen from closing automatically during live streaming.

● shared_preferences: in-app data storage library, used for reading and writing in-app data.

● video_compress : video compression library, used for video file compression.

● audioplayers: audio playback library, used to play audio files.

● encrypt_util: data encryption library, used for encrypting and decrypting data in the application.

● flutter_plugin_android_lifecycle : Application lifecycle management library, used to suspend and restart some resources before and after the application switch.

● flutter_vibrate : phone vibrate, used to realize phone vibrate alert effect.

● flutter_native_image: image processing library, used to compress image size.

● sqflite : database, used for in-app data storage and reading

● connectivity_plus: network connection library, used to get the current network connection type and prompt the user for action.

● soundpool : audio playback library, used to play sound effects.

● video_player_android : video player library, used for video preview playback. 

● video_thumbnail : library for getting video thumbnails, used to get video thumbnails for preview. in_app_purchase_android : In-app payment library, used for in-app payment function.

● Spines: Spine is a 2D skeleton animation editing tool for game development. This is used to allow you to see the usual prize effects.

● Zegos: It provides audio and video functions for the app to ensure that you can watch live broadcasts normally. Zego privacy policy link: https://www.zegocloud.com/privacy-policy

● package_info_plus: application information acquisition, used to get the application version and other information for display.

● emoji_picker_flutter : emoji selector, used to input emoji.

● audio_session: audio session manager, used for audio session management.

● FFmpeg: It is used to read the video frame and process the video when the user uploads a video post.

● Truetypeparser: This is used to crop the image when the user uploads an image post.

● Appsflyer:It is used to user download tracking,Privacy Policy：https://www.appsflyer.com/trust/privacy/ 

● Tencent Cloud IM-SDK: Provide long-link services for the app's live stream, video call and instant messaging features.Tencent Cloud IM-SDK privacy policy link: https://www.tencentcloud.com/document/product/1047/45407?lang=en&pg= Data Privacy and Security Agreement: https://www.tencentcloud.com/document/product/1047/45408