🌙

Privacy Policy

LuLu — Focus, Learn, Chill · Last updated: July 21, 2026

This Privacy Policy describes how Oleksandr Kostin ("we", "our", "us") handles information in connection with the LuLu — Focus, Learn, Chill iOS application (the "App"). We are committed to protecting your privacy.

1. Information We Collect

ON YOUR DEVICE

Data the App Stores

We do not operate any servers, and none of this information is sent to us:

Focus session history (date, duration, optional personal notes)
Streak progress, earned achievements and streak freezes
App preferences (theme, accent color, timer size, language)
Audio mixer settings (music, rain, café, keyboard, cat purr, train volumes)
Session reminder schedule (days and time of day)
Selected background scene and music style
Premium subscription status

YOUR ICLOUD

Sync Across Your Own Devices

So that your progress survives a new iPhone or a reinstall, the App syncs part of the data above through your own iCloud account, using Apple's CloudKit and iCloud Key-Value Storage. This covers:

Focus session history, including any notes you write
Streak state, freezes and earned achievements
App preferences, audio levels, timer and reminder settings

This data is stored in the private database of your personal iCloud account. It is governed by Apple's Privacy Policy and protected by your Apple Account. We have no access to it — we cannot read, retrieve, or delete it, and it never reaches any server operated by us.

Sync requires an iCloud account and iCloud Drive to be enabled. If you are not signed in to iCloud, or you turn iCloud off for LuLu in iOS Settings, the App keeps working and simply stores everything locally instead.

Data We Do NOT Collect

✓ No analytics or crash-reporting SDKs
✓ No advertising identifiers (IDFA)
✓ No usage or behavioral tracking
✓ No location data
✓ No contacts or photos access
✓ No accounts, sign-up or login of any kind
✓ No servers of our own — we receive no data at all
✓ No third-party SDKs that collect data

2. Permissions We Request

Notifications

We request permission to send local (on-device) notifications for optional session reminders you configure. We do not use push notifications. You can disable this at any time in iOS Settings → Notifications → LuLu.

Screen Time (Family Controls)

The "Full Concentration" feature optionally uses Apple's Screen Time API to block distracting apps during focus sessions. We do not access, read, or transmit any Screen Time data — the framework operates entirely within iOS and under your control.

3. In-App Purchases

Premium subscriptions are processed entirely by Apple via the App Store. We do not see, store, or process your payment information. For billing inquiries and refunds, please visit reportaproblem.apple.com.

Your subscription status is verified locally via Apple's StoreKit framework. No subscription data is transmitted to our servers.

4. Third-Party Services

The App does not integrate any third-party analytics, advertising, or data-collection services, and contains no third-party SDKs whatsoever.

The only external services involved are provided by Apple: the App Store for purchase processing, and iCloud (CloudKit) for syncing your data across your own devices, as described in Section 1. Both are governed by Apple's Privacy Policy. We receive no data from either.

5. Children's Privacy

The App is rated 4+ and appropriate for all ages. We do not knowingly collect any personal information from anyone, including children under 13. Because no personal data is collected or transmitted, the App complies with COPPA and equivalent children's privacy statutes.

6. Data Retention and Deletion

We retain nothing, because we receive nothing. Your data stays on your device and, if iCloud is enabled, in your own iCloud account. You can remove it at any time:

Individual sessions — delete them in the App's calendar view. Deletions sync to your other devices.
Preferences — reset them inside App Settings.
Everything on this device — delete the App. Note that this alone does not erase the copy held in your iCloud account, so reinstalling will restore your history.
The iCloud copy as well — on your device go to Settings → [your name] → iCloud → Manage Account Storage, select LuLu and delete its data. You can also turn sync off beforehand in Settings → [your name] → iCloud → Apps Using iCloud.

7. Data Security

No data is transmitted to any server operated by us. Data synced through iCloud is transmitted and stored by Apple, encrypted in transit and at rest under your Apple Account; if you enable Advanced Data Protection, it is end-to-end encrypted and not readable by Apple either.

Beyond that, the security of your data depends on the security of your device and your Apple Account. We recommend keeping iOS up to date, using Face ID or a passcode, and enabling two-factor authentication on your Apple Account.

8. Your Rights

Because we operate no servers and hold no copy of your information, every right below is exercised directly by you, on your device or through your Apple Account — there is nothing for us to retrieve, correct, or erase on your behalf.

If you are in the European Economic Area or the United Kingdom

Under the GDPR and UK GDPR you have the rights of access, rectification, erasure, restriction, portability, and objection. In practice:

Access and portability — all your data is visible inside the App; a full copy of the iCloud portion can be obtained from Apple at privacy.apple.com.
Rectification and erasure — edit or delete sessions in the App, and remove the iCloud copy as described in Section 6.
Objection and restriction — turn off iCloud sync for LuLu, or decline the optional notification and Screen Time permissions. The App remains fully usable.

The data controller for this App is named in Section 10. Where personal data is processed inside your iCloud account, Apple acts as the provider of that service under its own privacy policy. You also have the right to lodge a complaint with your national data protection supervisory authority.

We do not sell personal information, do not share it for cross-context behavioural advertising, and do not carry out automated decision-making or profiling.

9. Changes to This Policy

We may update this Privacy Policy from time to time. We will revise the "Last updated" date at the top. Continued use of the App after changes constitutes acceptance of the updated policy.

10. Contact and Data Controller

Oleksandr Kostin
Kyiv, Ukraine
Email: sashakostinua@gmail.com

Oleksandr Kostin is the data controller for the App and the trader responsible for its distribution.