About this notice
This notice supplements our Privacy Policy and applies to residents of California. It describes our practices under the California Consumer Privacy Act as amended by the California Privacy Rights Act (together, the “CCPA”). Even where the CCPA may not strictly apply to a business of our size, we choose to honour the rights below.
“Personal information” has the meaning in the CCPA. It does not include information that is deidentified, aggregated or publicly available.
Categories of personal information (last 12 months and going forward)
This table is our notice at collection. It covers the 12 months before the date above and what we expect to collect going forward. Where a category is marked “No”, we do not collect it.
| Category of personal information | Examples | Collected | Source | Business purpose | Disclosed to | Sold or shared | Retention |
|---|---|---|---|---|---|---|---|
| Identifiers | Email address (waitlist, support); IP address (website and room-clip delivery); app store transaction identifiers; a sign-in identifier if you choose an optional account in the future | Yes | You; your device, automatically; Apple or Google for purchases | Sending the launch email you asked for; replying to you; delivering the website and app content; security and debugging; processing purchases | Service providers (Cloudflare, which also stores the waitlist and sends its emails); Apple and Google for purchases | No | Waitlist: until you unsubscribe or 12 months after launch; unconfirmed sign-ups 7 days. Support: up to 24 months. IP logs: typically up to 30 days |
| Customer records (Cal. Civ. Code § 1798.80(e)) | Your name, if you include it in an email to us | Yes | You | Replying to you and providing support | Service providers (our email provider) | No | Up to 24 months after the conversation ends |
| Protected classification characteristics | Age, gender, race, religion and similar | No | — | — | — | No | — |
| Commercial information | In-app purchases and Lulopi Club status (product, purchase or renewal status), once purchases are available | Yes | Apple or Google | Providing and restoring what you bought; customer support; accounting | Apple and Google (which process the transaction); professional advisers for accounting | No | As long as needed to provide the content; accounting records generally 7 years |
| Biometric information | Face or fingerprint data | No | — | — | — | No | — |
| Internet or other electronic network activity | Pages and files requested, time of request, browser or device type, referring page | Yes | Your device, automatically | Delivering the website and room clips; security, fraud prevention and debugging | Service providers (Cloudflare) | No | Typically up to 30 days |
| Geolocation data | Precise location. (Our hosting provider may infer an approximate region from your IP address to route traffic; we don’t use it to locate you.) | No | — | — | — | No | — |
| Sensory data | Audio, photos or video of you | No | — | — | — | No | — |
| Professional or employment information | Job title, employer | No | — | — | — | No | — |
| Education information | Student records | No | — | — | — | No | — |
| Inferences | Profiles about your preferences or characteristics | No | — | — | — | No | — |
| Sensitive personal information | Government IDs, financial account details, precise geolocation, health data, account log-in credentials | No | — | — | — | No | — |
| App data stored on your device | Your kitten’s name, state, progress, keepsakes, memories, small things and settings | No | Stays on your device; we don’t receive it | — | — | No | Until you delete it or the app |
If we introduce an optional account with cloud sync, we will update this table before launch to cover the sign-in identifier and the companion data you choose to sync.
Do Not Sell or Share My Personal Information
We do not sell your personal information, and we do not share it for cross-context behavioural advertising. We have not done so in the past 12 months. There are no third-party ads in Lulopi.
Because we don’t sell or share, there is nothing you need to opt out of. If that ever changed, we would update this notice first and give you a clear way to opt out. We treat a Global Privacy Control (GPC) signal from your browser as a valid request to opt out of sale and sharing.
Sensitive personal information
We do not collect sensitive personal information as defined by the CCPA. If we introduce optional accounts, any log-in credentials would be used only to provide the account and keep it secure, which are permitted purposes, so there would be no need to limit their use. We do not use or disclose sensitive personal information to infer characteristics about you.
Your California privacy rights
- Right to know and access the categories and specific pieces of personal information we have collected about you, the sources, the purposes and the recipients.
- Right to delete personal information we collected from you, subject to legal exceptions.
- Right to correct inaccurate personal information.
- Right to opt out of sale or sharing. We don’t sell or share, as explained above.
- Right to limit use of sensitive personal information. We don’t collect it.
- Right to non-discrimination. We won’t deny you service, charge you a different price or give you a different quality of service because you exercised your rights.
How to submit a request
Email support@lulopi.my with the subject “California privacy request”, and tell us which right you’d like to use. As an online-only service with a direct relationship with you, email is our designated method for requests.
- Verification. To protect you, we’ll verify your request by matching information you give us with what we hold, for example by confirming from the email address you used with us. We only use this information to verify your request.
- Authorised agents. You can use an authorised agent. We may ask for proof of their authority, signed by you, and ask you to verify your identity directly.
- Timing. We’ll confirm receipt within 10 business days and respond within 45 calendar days. If we need more time (up to a further 45 days), we’ll tell you why.
- Remember: most app data stays on your device and never reaches us. You can delete it by deleting the app.
Minors
Lulopi is a general-audience app and is not directed at children under 13. We do not sell or share the personal information of consumers under 16, and we have no actual knowledge of doing so. If you believe we hold personal information about a child under 13, contact support@lulopi.my and we will delete it.
Shine the Light and Do Not Track
Under California Civil Code § 1798.83, California residents may ask about disclosures of personal information to third parties for their own direct marketing. We make no such disclosures. Our website does not track you across third-party sites, so it responds to “Do Not Track” signals in the same way as any other visit; we also honour Global Privacy Control as described above.
Contact
Sansa Group AB (Lulopi is made by Sansavision, a division of Sansa Group AB)
Org. no. 559111-9507
Soldathemsgatan 20, 415 28 Göteborg, Sweden
Questions and privacy requests: support@lulopi.my