LucaLuca.ai Privacy Policy
Version: 1.1
Effective date: December 25, 2025
Data Controller: Monsoon Labs Oy, 3552238-6, Finland
This is the privacy policy of LucaLuca, an AI-powered photo editing app provided by Monsoon Labs Oy.
Age Rating and Audience (13+)
- Age rating: 13+. You must be at least 13 years old (or the minimum age of digital consent in your country, if higher).
- We do not knowingly collect personal data from children under 13; if we learn that a child has provided personal data, we will delete it.
Information We Collect
Your Photos
When you select photos to edit, we temporarily upload them to cloud servers so our AI can process them. We only handle photos you specifically choose for editing — we never access your entire photo library.
Your photos are processed by third-party AI services (including services located in the United States) that may be located anywhere in the world, including outside Europe. These processing activities may involve international transfers to countries with different data protection laws. We do not use your photos to train generalized machine-learning models. Our providers are contractually prohibited from using your photos for model training and are instructed to process them only to provide the Service.
We only use your photos to provide the editing service you requested — nothing else.
Retention: Uploaded photos (source photos) are retained for 24–48 hours, then automatically deleted. Generated photos are retained by third-party AI processing services temporarily (typically for a short period necessary for processing), then automatically deleted.
Error and Crash Logs
We use an error monitoring service (Sentry) to collect crash reports and diagnostics so we can fix bugs, keep the app secure, and improve performance. This data may include device model, operating system version, app version, timestamps, language/locale, anonymized IP address at ingestion, stack traces, and event metadata (for example, which screen was open when an error occurred). We do not set a persistent user identifier in Sentry. We configure Sentry to avoid collecting your photos or their contents and to remove or mask obvious personal data where possible.
Legal basis: Our legitimate interests in maintaining and improving the App.
Retention: Crash and error data is retained for up to 90 days, then deleted or anonymized.
App Usage Analytics
We collect anonymous usage analytics to improve the App. This data cannot be used to identify you.
Legal basis: Our legitimate interests in improving the App.
Purchase Information
We receive confirmation from Apple when you make in-app consumable purchases so we can enable the purchased features or credits. We do not receive your payment card details, billing address, or full payment information; all billing is handled by Apple.
- Source: Apple (purchase status/receipts are provided to us by Apple and not directly by you).
- Legal basis: Performance of a contract and our legal obligations (for example, accounting/tax).
- Retention: Purchase verification records are kept for as long as necessary to operate the purchase and as required by applicable laws.
Contact Info
If you email us, we'll receive your email address and the contents of your message, which we use to help you.
How We Share Your Data
Photos: Only with our cloud providers and AI services to edit them for you.
Other info: We don't sell your data. We only share it with:
- Service providers that help us run the app (hosting, processing, analytics, error monitoring) under contracts
- Apple, to verify and manage in-app consumable purchases made through the App Store
- Authorities when legally required
Sharing Features
When you choose to share edited photos (for example, to social apps or via links), we pass your chosen content to iOS and the destination you select. Your sharing activity is governed by the destination's terms and privacy policies. We do not control how third parties handle your content.
Your Rights
Depending on where you live, you may have rights over your personal data (for example, to access, delete, correct, restrict or object to processing, or receive a copy). To exercise these rights, email us at support@monsoonlabs.dev. We will respond as required by applicable law.
Important Notes
International transfers: Your data may be processed outside your country, including in countries with different privacy laws.
Security: The security of your personal data is important to us. We strive to use commercially acceptable means to protect your data, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we use standard security practices, we cannot guarantee absolute security.
Unrestricted web access: The Service does not provide unrestricted web browsing.
Changes: We may update this policy from time to time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it in the app. Any modifications will be effective upon posting the new policy. Your continued use of our Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
Contact Us
Questions? Email us at support@monsoonlabs.dev.