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App Privacy

App Privacy Policy

The Luka AI Robot App is intended only for parents or legal guardians of children who interact with the Luka AI Robot. This Policy explains how we collect, use, store, disclose, and share your personal information when you use the App.

Last updated

May 19, 2026

Effective date

May 19, 2026

Reading time

~18 min

On this page

Welcome to the Luka AI Robot App. The Luka AI Robot App (the "App") is intended only for parents or legal guardians of children who interact with or use the Luka AI Robot (the "Robot", collectively "Services"), and is provided to support parental supervision and management of children's use of the Robot.

This Luka AI Robot App Privacy Policy (the "Policy") explains how we collect, use, store, disclose and share (collectively, "process") your personal information when you use the App. Our Children's Privacy Notice supplements this Policy and describes our privacy practices related to children's personal information.

In this Policy, "Lingverse", "we", "us" or "our" refers to Lingverse Technology Pte. Ltd., a company registered in Singapore. We care about the protection and confidentiality of your information. We process your personal information only as described in this Policy. If you have any questions regarding this Policy, please contact us according to the information listed below under the Section "Contact Us".

01

Personal Information We Collect

For the purpose of this Policy, "personal information" means any information relating to an identified or identifiable individual. In certain jurisdictions, this may be referred to as "personal data". However, for the sake of consistency, this Policy will use the term "personal information" throughout to refer to such data. To the extent that our processing of your personal information is subject to certain data privacy protection laws (including but not limited to the General Data Protection Regulation ("GDPR"), California Consumer Privacy Act of 2018 ("CCPA"), California Privacy Rights Act of 2020 ("CPRA"), etc., collectively hereafter "applicable laws"), we will also notify you about the legal basis on which we process your personal information and your rights under such laws.

1.1.Information you provide

Through your use of the Services, you may provide us with the following information:

  • Account Data: When you create an account and/or log in to our Services, we will collect your phone number, verification code, and password.

  • Profile Data: After you have created and logged into your account, you may further edit your profile information, by providing your profile photo and username.

  • Child Profile Data: During registration or your subsequent use of the App, you may choose to provide information about your child, including your child's gender, nickname, profile photo, and date of birth.

  • Robot Connection Data: When you connect your Robot to the App, we will collect the Robot's type. To connect your Robot to the Internet, we may also collect the name of your Wi-Fi network and your Wi-Fi password.

  • Robot Command Data: When you use the App to remotely control a connected Robot, we may collect your device commands, such as commands to power the Robot on or off, adjust the volume, or schedule playback.

  • Messaging Data: When you send messages through the App to your child who uses a connected Robot, we may collect the message records between you and your child, including voice messages, text messages, and emojis.

  • User-Generated Content: When you use the recording or camera features in the App, we may collect the photos, images, audio recordings, and other content that you choose to provide.

  • Delivery Recipient Information: When you purchase products or services through the App, we may collect the delivery recipient's name, delivery address, and contact phone number that you provide.

  • Customer Support Data: When you contact us through customer support or similar features, we may collect your contact information, communication records, and information relating to your requests or inquiries.

1.2.Information we collect automatically

In order to provide secure and continuous services, maintain service quality, and provide personalized features, we may also automatically collect the following information from you:

  • Device and Network Data: This includes your IP address, MAC address, unique device identifiers, login IP address, device model, device name, device identifiers, browser type and settings, language settings, operating system and App version, method of network access, network quality data, mobile network information (including carrier name), product version number, location information.

  • Log Data: This includes your browsing history, search history, audio and video playback history, the date and time of access.

  • Service Order Data: This includes information about the products or services you purchase, transaction amount, order time, merchant, order number, order status, payment method, payment account, and payment status.

02

How We Use Your Information

We will only use your personal information when the applicable laws allow us to. Our legal bases for collecting and using the personal information described in this Policy depends on the personal information we collect and the specific context in which we collect the information:

  • We need to perform a contract with you;

  • You have given us consent to do so;

  • In specific jurisdictions, processing your personal information is in our legitimate interests, including: providing, maintaining and marketing our Services; detecting, preventing and enforcing violations of our Terms of Use including misuse of services, fraud, abuse, and other trust and safety protocols; and protecting our legal rights and the rights of others.

  • We need to comply with our legal obligations under the applicable laws.

The purposes for which we process personal information, subject to applicable laws, and the legal basis on which we perform such processing, are as follows:

Purpose

Type of Personal Information

Legal Basis

To provide you with functions related to user account management, such as account registration, account deletion, account login, and modification of account profile information

  • Account Data

  • Profile Data

  • Device and Network Data

Performance of contract

To enable you to create and manage your child's profile through the App

  • Account Data

  • Child Profile Data

Consent

To provide you with functions related to Robot control, such as pairing and unpairing the Robot with your account, and controlling the Robot by sending commands

  • Account Data

  • Robot Connection Data

  • Robot Command Data

  • Device and Network Data

  • Log Data

Performance of contract

To enable you to send messages through the App to your child using a connected Robot

  • Robot Connection Data

  • Messaging Data

Performance of contract & Consent, where required by applicable laws

To provide recording and camera features through the App

  • Profile Data

  • User-Generated Content

Performance of contract

To provide you with the paid services

  • Account Data

  • Delivery Recipient Information

  • Service Order Data

Performance of contract

To provide you with customer support services

  • Account Data

  • Profile Data

  • Robot Connection Data

  • Customer Support Data

  • Device and Network Data

  • Service Order Data

Legitimate interests & Performance of contract & Consent, where required by applicable laws

To communicate with you for non-marketing purposes including by sending you Services-related notices, push notifications, and other messages

  • Account Data

  • Device and Network Data

Performance of contract

To send you marketing communications, where you have signed up to receive them

  • Account Data

Consent

To monitor and protect the Services to ensure the normal operation of the services you use, including preventing fraud, criminal activity, and misuse of our Services

  • Account Data

  • Robot Command Data

  • Messaging Data

  • User-Generated Content

  • Device and Network Data

  • Log Data

Performance of contract & Legitimate interests

To comply with legal obligations, and defend against legal claims and disputes

  • Account Data

  • Profile Data

  • Child Profile Data

  • Robot Connection Data

  • Robot Command Data

  • Messaging Data

  • User-Generated Content

  • Delivery Recipient Information

  • Customer Support Data

  • Device and Network Data

  • Log Data

  • Service Order Data

Legal Obligations & Legitimate interests & Consent, where required by applicable laws

Purpose

To provide you with functions related to user account management, such as account registration, account deletion, account login, and modification of account profile information

Type of Personal Information

  • Account Data

  • Profile Data

  • Device and Network Data

Legal Basis

Performance of contract

Purpose

To enable you to create and manage your child's profile through the App

Type of Personal Information

  • Account Data

  • Child Profile Data

Legal Basis

Consent

Purpose

To provide you with functions related to Robot control, such as pairing and unpairing the Robot with your account, and controlling the Robot by sending commands

Type of Personal Information

  • Account Data

  • Robot Connection Data

  • Robot Command Data

  • Device and Network Data

  • Log Data

Legal Basis

Performance of contract

Purpose

To enable you to send messages through the App to your child using a connected Robot

Type of Personal Information

  • Robot Connection Data

  • Messaging Data

Legal Basis

Performance of contract & Consent, where required by applicable laws

Purpose

To provide recording and camera features through the App

Type of Personal Information

  • Profile Data

  • User-Generated Content

Legal Basis

Performance of contract

Purpose

To provide you with the paid services

Type of Personal Information

  • Account Data

  • Delivery Recipient Information

  • Service Order Data

Legal Basis

Performance of contract

Purpose

To provide you with customer support services

Type of Personal Information

  • Account Data

  • Profile Data

  • Robot Connection Data

  • Customer Support Data

  • Device and Network Data

  • Service Order Data

Legal Basis

Legitimate interests & Performance of contract & Consent, where required by applicable laws

Purpose

To communicate with you for non-marketing purposes including by sending you Services-related notices, push notifications, and other messages

Type of Personal Information

  • Account Data

  • Device and Network Data

Legal Basis

Performance of contract

Purpose

To send you marketing communications, where you have signed up to receive them

Type of Personal Information

  • Account Data

Legal Basis

Consent

Purpose

To monitor and protect the Services to ensure the normal operation of the services you use, including preventing fraud, criminal activity, and misuse of our Services

Type of Personal Information

  • Account Data

  • Robot Command Data

  • Messaging Data

  • User-Generated Content

  • Device and Network Data

  • Log Data

Legal Basis

Performance of contract & Legitimate interests

Purpose

To comply with legal obligations, and defend against legal claims and disputes

Type of Personal Information

  • Account Data

  • Profile Data

  • Child Profile Data

  • Robot Connection Data

  • Robot Command Data

  • Messaging Data

  • User-Generated Content

  • Delivery Recipient Information

  • Customer Support Data

  • Device and Network Data

  • Log Data

  • Service Order Data

Legal Basis

Legal Obligations & Legitimate interests & Consent, where required by applicable laws

03

How We Share Your Personal Information

In order to provide you with more comprehensive and high-quality Services, we will authorize our commercial partners to provide certain services to you. In such cases, we may share some of your personal information with our partners.

We will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and we will only share the personal information required to provide the Services. We will require our partners, through agreements, to retain data only for the necessary period and to implement adequate security measures to protect data security.

We will disclose personal information to the following categories of third parties for the purposes explained in this Policy:

  • Affiliates and corporate partners. We disclose the categories of personal information described above between and among our affiliates and related entities, for legitimate business purposes and the operation of the Services, in accordance with applicable laws.

  • Service providers and business partners. Third-party service providers who provide us with technology services (such as cloud storage service) and business support (such as payment service provider) may need to process your data. These third parties will process your personal information on our behalf under relevant contracts.

  • Law enforcement agencies, public authorities or other judicial bodies and organizations. We disclose your personal information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our Terms of Use and other terms, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by applicable laws (including exchanging information with other companies and organizations for the purposes of fraud protection).

  • Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your information as part of that transaction.

04

How We Transfer Your Data Around The World

We will process your personal information on servers located in the United States. To support our global operations, we may allow remote access from Mainland China for troubleshooting and other technical support. What's more, your personal information may also be transferred to third-party service providers and business partners, in connection with the purposes set out in this Policy. Accordingly, your personal information may be transferred to and processed in jurisdictions that may have different laws and data protection compliance requirements to those that apply in the jurisdiction in which you are located.

In the event of an international transfer of personal information, when required by applicable laws, we will provide an adequate level of protection for your personal information using various means to enable lawful transfer of personal information from those countries. If you would like to have an overview of the safeguards which are in place, please contact us by using the contact details provided in Section "Contact Us" below.

05

How We Secure Your Information

We have implemented appropriate technical and organizational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable laws.

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. If you have any concerns that your account or personal information has been put at risk, for example if someone could have found out your password, please contact us by using the contact details provided in Section "Contact Us" below.

Please note, the Internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal information, we cannot guarantee the security of your data transmitted to us using the Internet — any such transmission is at your own risk, and you are responsible for ensuring that any personal information that you send to us are sent securely.

06

How Do We Retain Your Personal Information

We adhere to retention policies for the personal information we collect to ensure that it is not retained longer than necessary for the intended purpose.

If you deactivate your account, delete personal information, or the retention period is expired, we will delete or anonymize your personal information, except in the following cases:

  • Compliance with legal requirements regarding data retention according to the applicable laws.

  • Extension of the period for financial, audit, dispute resolution, or other legitimate purposes.

When assessing how long your personal information is retained, we consider criteria such as: (i) the nature of the personal information and the activities involved; (ii) when and for how long you use the Services; and (iii) our legitimate interests and our legal obligations.

07

Your Rights and Choices

Subject to applicable law and depending on where you reside, you may have some rights regarding your personal information, as described below. If you have any other requests relating to the access of your personal information, please contact us using the contact details listed in the Section "Contact Us".

7.1.Data Access

You may have the right to know what personal information we process about you, including the categories of personal information, the business or commercial purposes for collection, and the categories of third parties to whom we disclose it, and other information according to the applicable law.

7.2.Data Correction

You may have the right to request that we correct inaccurate personal information that we retain about you, subject to certain exceptions.

7.3.Data Portability

You may contact us to request the personal information you have provided to us in a structured, commonly used and machine-readable format and have it transferred to another controller, to the extent applicable.

7.4.Data Deletion

You have the right to delete your account and erase your personal information. Upon deleting your account, all your personal information will be deleted promptly. Additionally, you may also request deletion of the personal information you provide by contacting us. If some of your personal information cannot be deleted, we will inform you of the reasons for not taking action.

Please note that we reserve the right to retain some of your personal information where there are valid grounds for us to do so under applicable laws.

7.5.Withdrawal of Consent

Where we process your personal information on the basis of your consent, you may withdraw your consent by contacting us. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

In the event that we use your personal information for marketing in compliance with legal requirements, you have the right to opt out of future direct marketing messages through the unsubscribe mechanism at the bottom of such communications, or contacting us.

7.6.Objection to the Processing

Subject to applicable laws, you may object to the processing of your personal information based on our legitimate interests where there are grounds relating to your particular situation by contacting us. Please note that we may have an overriding legitimate interest to keep processing your personal information, but we will let you know where this is the case.

7.7.Restriction to the Processing

If you would like to restrict our processing of your personal information, you may contact us. You have the right to restrict the processing of your data where one of the following applies:

  • the processing is unlawful and you oppose the erasure of relevant personal information;

  • for the purpose of establishment, exercise or defense of legal claims, you request us to retain your personal information that we were supposed to delete;

  • your objection regarding the accuracy of your personal information is pending our verification;

  • your request to object to the processing of your personal information is pending our verification.

7.8.Other Rights

Depending on your jurisdiction, you may be entitled to additional rights in relation to your personal information. For example, you may also have the right to lodge complaints with an applicable data protection authority if you consider that the processing of your personal information infringes any applicable data protection laws (for example, the EU General Data Protection Regulation). For California residents, please find more details of your rights in Section 8 below.

If you would like to contact us to exercise one or more of these rights, to ask a question about these rights or any other provision of this Policy or about our processing of your personal information, or to file a complaint about how we process your personal information, you may use the contact details provided in Section "Contact Us" below. When submitting a right request, please specify the scope and basis of your request and provide us with the necessary information to verify your identity. We may contact you to confirm your identity in order to handle your request. We will respond to your request or complaint in due course under applicable data protection laws.

08

Notice to California Residents

If you are a California resident, the California Consumer Privacy Act ("CCPA") requires us to provide you with the following additional information:

8.1.Collection and Use of Your Personal Information

We collect personal information from and about you in the preceding 12 months as described in Section 1 above, primarily including the following categories of personal information enumerated under the CCPA definition of "personal information":

  • Identifiers, such as username, contact information, IP address and other device identifiers.

  • Personal information categories listed in the California Customer Records statute, such as name and phone number.

  • Internet and similar network activity information, such as information regarding your interactions with the Services.

  • Geolocation information, such as IP address and location information.

  • Commercial information, such as your transaction records.

  • Characteristics of protected classifications, such as age and gender, where you choose to provide such information as part of your child's profile.

  • Audio, electronic, visual, or similar information, such as voice messages, audio recordings, photos, images, videos, and similar content that you choose to provide through the Services.

  • Sensitive personal information, such as your account password, and personal information of your child under age of 16.

8.2.Disclosure of Personal Information

We disclose personal information with third parties for business purposes in the preceding 12 months as described in Section 3 above. The details are as follows:

Categories of Personal Information Disclosed

Categories of Recipients

Identifiers

  • Lingverse affiliates

  • Service providers and business partners

Personal information categories listed in the California Customer Records statute

  • Lingverse affiliates

  • Service providers and business partners

Internet and similar network activity information

  • Lingverse affiliates

  • Service providers and business partners

Geolocation information

  • Lingverse affiliates

  • Service providers and business partners

Commercial information

  • Lingverse affiliates

  • Service providers and business partners

Characteristics of protected classifications

  • Lingverse affiliates

  • Service providers and business partners

Audio, electronic, visual, or similar information

  • Lingverse affiliates

  • Service providers and business partners

Sensitive personal information

  • Lingverse affiliates

  • Service providers and business partners

Categories of Personal Information Disclosed

Identifiers

Categories of Recipients

  • Lingverse affiliates

  • Service providers and business partners

Categories of Personal Information Disclosed

Personal information categories listed in the California Customer Records statute

Categories of Recipients

  • Lingverse affiliates

  • Service providers and business partners

Categories of Personal Information Disclosed

Internet and similar network activity information

Categories of Recipients

  • Lingverse affiliates

  • Service providers and business partners

Categories of Personal Information Disclosed

Geolocation information

Categories of Recipients

  • Lingverse affiliates

  • Service providers and business partners

Categories of Personal Information Disclosed

Commercial information

Categories of Recipients

  • Lingverse affiliates

  • Service providers and business partners

Categories of Personal Information Disclosed

Characteristics of protected classifications

Categories of Recipients

  • Lingverse affiliates

  • Service providers and business partners

Categories of Personal Information Disclosed

Audio, electronic, visual, or similar information

Categories of Recipients

  • Lingverse affiliates

  • Service providers and business partners

Categories of Personal Information Disclosed

Sensitive personal information

Categories of Recipients

  • Lingverse affiliates

  • Service providers and business partners

8.3.Additional Rights for California Residents

In addition to the personal information rights listed in Section 7 above, you are also entitled to the following:

  • Limit the Use of Sensitive Personal Information. You also have the right to request limitation of use and disclosure of your sensitive personal information, subject to certain exceptions. If you would like to limit the use of your sensitive personal information, please contact us by using the contact details provided in Section "Contact Us" below.

  • Do Not Sell or Share My Personal Information. Based on the definition of "sell" and "share" under the CPRA, we do not believe that we engage in such activity and have not engaged in such activity in the past 12 months from the effective date of this Policy.

  • We may share your personal information with third-party advertising partners for ad targeting and analytics purposes. Under the California Privacy Rights Act (CPRA), this type of sharing may be considered a "sale" or "share" of your personal information. You have the right to opt out of such sharing. Please use the link below to exercise your right: Do Not Sell or Share My Personal Information.

  • Direct Marketing. We do not disclose personal information to third parties for their direct marketing purposes.

  • Appeal. You may appeal our refusal to take action on a request by contacting us using the contact details provided in Section "Contact Us" below. If your appeal is denied and you are a California resident, you may contact the California Attorney General about the results of the appeal by submitting a complaint at oag.ca.gov/contact/consumer-complaint-against-business-or-company.

  • Right not to be subject to automated decision-making. You shall have the right not to be subject to automated decision-making. You also have the right to obtain your personal information used for automated decision-making, to be informed of the reasons of the resulting decision, and to be informed of what actions you can take to secure a different decision.

  • The Right to Non-discrimination. You have a right to not be discriminated against for exercising any of your rights.

If you would like to contact us to exercise one or more of these rights, to ask a question about these rights or any other provision of this Policy or about our processing of your personal information, or to file a complaint about how we process your personal information, you may use the contact details provided in the Section "Contact Us" below. According to applicable laws, we may request you to provide documents such as application form and proof of identity. We may contact you to confirm your identity in order to handle your request. We will respond to your request or complaint in due course under the applicable laws.

09

Use by Minors

We recognize the need to provide further privacy protections with respect to personal information we may collect from children (in the EU, referring to users under 16; in the US, referring to users under 13, or under such other age as defined or required under applicable laws in the jurisdiction where the user is located) through our Services. When we intend to collect personal information from children, we take additional steps to protect children's privacy, including:

  • Notifying parents about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information;

  • In accordance with applicable law, and our practices, obtaining consent from parents for the collection of personal information from their children, or for sending information about our products and services directly to their children;

  • Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity; and

  • Giving parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted.

For additional information about our practices in the United States regarding children's personal information, please read our Children's Privacy Policy.

10

Changes to This Privacy Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Policy. We recommend that you regularly check the latest version of this Policy in the App. If there are any substantial changes to this Policy, depending on the nature of such changes, we will notify you in advance through pop-ups, push notifications, and other appropriate means.

11

Contact Us

For more information about your data subject rights, or how we process your personal information, please contact us using the information below:

Lingverse Technology Pte. Ltd.
Address: PAYA LEBAR SQUARE 60 PAYA LEBAR ROAD #12-003 Singapore 409051
Email: privacy@luka.world

If you use our Services within the European Economic Area, we have designated our EEA representative in accordance with Article 27 of the GDPR. For details, please contact us at privacy@luka.world.

✦ Still have questions?

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Questions, complaints, or claims about these Terms or your Account — drop our team a line and we'll get back within two business days.

privacy@luka.world