Effective Date: 08/03/2024
This Privacy Policy sets out how Lungy uses and protects any information that the users of this App give while using this app. This privacy policy should be read in conjunction with our Terms and Conditions and the Medical Disclaimer. Please read this privacy policy carefully as we will not be held responsible in case there is a breach of this policy on your part.
1. GENERAL
a. Lungy is committed to protecting and respecting your privacy in compliance with the European Union's General Data Protection Regulation (GDPR) and the UK's Data Protection Act 2018.
b. Lungy does not request or require any personal identifiable information such as name, email address, date of birth, or address for functionality.
c. Downloading, accessing, or otherwise using this App indicates that you have read this privacy policy and consent to its terms. If you do not consent to the terms of this privacy policy, please do not download, access, or otherwise use this App.
d. If you are a minor in the jurisdiction in which you reside, you may use this App only with the consent of your parent or legal guardian. We will not be held liable for any cause of action due to a breach of this privacy policy.
2. INFORMATION WE COLLECT
a. Lungy does not currently collect or require any personal identification information such as name, email address, date of birth, gender, and country to access and use the app. There is no login screen or registration to access the app.
b. You may be expected to provide your financial details (such as credit or debit card details) via your Apple ID, to the Apple App Store in order to become a paid subscriber or purchaser of this App. Additionally, Lungy may collect purchase data to aid with managing and handling user subscriptions, purchases, and promotions. This data may be collected but is not linked to your identity and only stored with anonymous App User IDs.
c. Lungy uses the microphone to recognize and respond to user breathing. No audio or microphone data is ever recorded, streamed, transmitted, or stored. The microphone data is analyzed and stored as encrypted numerical breathing data after each breathing exercise you complete. This data is entirely anonymized, the data remains on your device and is on-device encrypted.
d. Additionally, Lungy can use the camera (with TrueDepth on supported devices), with subsequent face-tracking, to help you position the phone for optimal breathing detection. The use of the camera positioning screen is entirely optional and at the user's discretion. No depth (including all TrueDepth data), video or camera data is ever recorded, streamed, transmitted or stored. No identifiable or recognizable face or face-tracking data is ever stored, and is only used for the purpose of tracking the positioning and orientation of the face. The positioning and any facial tracking data is not saved to the device at any time and these data only exist whilst i) a user's face is detected and ii) the camera positioning screen is visible to the user and will be immediately deleted and unrecoverable as soon as: i) a user's face is no longer detected and/or ii) the camera positioning screen is no longer visible or active. Similarly, TrueDepth data is never shared with any third parties, and does not leave the device. Additionally, it is not saved to the device at any time. If you would prefer to not use this face-tracking feature, please select 'Without Camera' during the tutorial, or set Face-Tracking to Off in 'Settings'.
e. Your privacy is a priority to us. For this reason, Lungy does not share any identifiable or user information with remote or cloud servers, it is not transferred, and stays on your device.
3. ADDITIONAL DATA COLLECTION FOR USAGE DATA AND PURCHASE TRACKING
a. For the purpose of tracking in-app purchases and managing subscriptions, Lungy uses the RevenueCat API. This API tracks purchase transactions via anonymized IDs, ensuring that purchase data is not linked to your personal identity.
b. To better understand user interactions and improve app functionality, Lungy utilizes Mixpanel for analytics. This tool allows us to collect anonymized data on app usage patterns, ensuring that no personally identifiable information is linked to the data collected. By analyzing these insights, we can enhance our services, develop features that better meet our users' needs, and optimize the overall user experience. All data collection is done with a strong commitment to protecting your privacy.
4. HOW DO WE COLLECT YOUR PERSONAL INFORMATION
a. We only collect information from you directly through this App.
5. HOW DO WE USE YOUR PERSONAL INFORMATION
a. We may use the information collected through this App for the following:
i. Improve our services and how we operate our App;
ii. Market research activities to offer you better services;
iii. Marketing and promotional purposes to spread a message about our App;
iv. Enhance the user experience for using this App, our products, and services;
v. Personalize our services and make recommendations;
vi. User authentication to ensure the safety and security of your account;
vii. Provide and deliver products and services at your request;
viii. Protect, investigate, and deter fraudulent, unauthorized, or illegal activity.
b. Apart from the above, we may also use information collected through this App for record keeping, quality control, and for sending promotional materials.
c. We do not use your personal information for commercial purposes.
d. We do not give access to any third parties any personal data, camera data, any face/face-tracking data, microphone data, usage data, or breathing data. These data will never leave your device and will never be stored by us or any third parties.
6. DATA STORAGE AND TRANSFER
a. All breathing and personal data is stored on your device and is on-device encrypted. Additionally, please ensure you set a passcode on your device for added security.
7. DATA SECURITY
a. Your personal information, breathing, and progress data will be stored locally on your device and encrypted. Please ensure you set a passcode on your device for added security.
b. We are committed to ensuring that your data including personal information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
c. Any information we collect will remain confidential and apart from us, no one else will be able to access this data.
d. Once you delete your account on our App, your personal information will be automatically deleted.
e. If you would like to know the details of your personal information which we hold, please write to us at hello@lungy.app.
8. COOKIES AND OTHER TECHNOLOGIES
As of date 9th December 2023, we do not use cookies or other similar technologies. If you have any feedback or complaint against our App or website, please write to us at: hello@lungy.app.
9. YOUR RIGHTS
a. If you are a registered user of our App, we offer you an opportunity to review, correct, update, or delete your personal information. You can do this by either of the following ways:
i. By emailing us at: hello@lungy.app
b. You have the right to ask us not to process your personal information for marketing, promotional, and research purposes. You can exercise your right to prevent such processing by checking or unchecking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at: hello@lungy.app.
10. SHARING OF PERSONAL INFORMATION
a. We do not share your personal information with third-parties without your prior consent except:
i. To comply with applicable laws or respond to lawful requests and legal processes.
ii. To protect our rights and property, our agents, our customers, to enforce our agreements, policies, and terms of use.
iii. In an emergency such as to protect the personal safety of any person.
11. LINKS TO OTHER WEBSITES & APPS
a. Our App and website may be connected to third-party websites and apps. It is your responsibility to ensure that you adhere to the Apple Store’s Privacy Policy.
b. Our App and website may contain links to other websites or mobile applications. However, once you leave our App or website, we have no control over third-party websites and mobile applications. We are not responsible for protecting your privacy on these third-party websites and mobile applications. You should conduct due diligence and carefully read the privacy policies applicable to the website or App in question.
12. COMPLAINT AND DISPUTE RESOLUTION
a. If you have any complaint or concern regarding your personal information under this privacy policy, please contact us at: hello@lungy.app. We suggest that you put in the subject line of any email or communication “Privacy Policy” or “Privacy Complaint.” We will try our best to respond within 45 days.
b. In the event of any dispute or claim arising out of or relating to the use of your personal information, you will attempt in good faith to negotiate a written resolution of the matter directly with us. If the matter remains unresolved for sixty days after notification (via email, certified mail, or personal delivery) that a dispute exists, the parties will attempt to resolve the matter via mediation. The parties shall mutually agree to appoint a mediator.
c. Under no circumstance, will the parties resolve the dispute by arbitration, litigation, or jury trial except if required by law.
13. CHANGES TO THIS POLICY
a. Our privacy policy is subject to change at any time without notice. Please review this policy periodically to make sure that you are aware about the changes. We will not beheld responsible if you are not aware about the recent changes to the policy. The recent changes can be found at the top of this policy.
b. This policy is effective from 13/11/2022. If you have any questions related to this privacy policy or how we handle your personal information, please contact us at hello@lungy.app. You may also contact our Data Protection Officer directly.
These Terms are effective and were last updated on 09/12/2023
Lungy (developed by Pi-A) is based out of London, United Kingdom.