Liloo — Privacy Policy

Last updated: 2026-09-02 Contact: privacy@liloosafespace.com

This Privacy Policy explains what data the Liloo mobile application (application ID com.liloosafespace.app) and the website at liloosafespace.com process, for what purposes, on what legal basis, with whom the data is shared, and how you can control it.

What Liloo is. Liloo is a communication-skills training app. You hold a conversation with AI characters that play the role of difficult interlocutors (for example, a conflict-prone relative or an aggressive colleague) so you can safely rehearse handling tense situations. The app also includes a "Training" mode and audio meditations. For an AI character to reply, the text of your message is sent to our servers and to a third-party language-model provider (see Section 4).

1. Who processes your data (data controller)

The data controller is FOP Rudenko Yevheniia Yevhenivna (an individual entrepreneur registered in Ukraine), the developer and operator of the Liloo app.

For any privacy question, to exercise your rights, or to request deletion, contact:

Email: privacy@liloosafespace.com

2. Data we collect

We do not access your contacts and we do not collect your location or an advertising identifier. The app requests permissions for the camera (avatar photo), the microphone and iOS speech recognition (system dictation), and notifications (push) — each used only for that feature.

3. Purposes and legal basis

We process your data to:

• Provide the core feature — generate the AI character's replies to your messages, the "Training" mode, and meditations.
• Support dictation — convert speech into editable text that you can review before sending.
• Store your avatars, dialogues and history — so you can continue sessions and track progress.
• Manage subscriptions — process in-app purchases and your subscription entitlement.
• Keep the service safe — detect crisis situations (e.g. mentions of self-harm), harmful or prohibited content, and attempts to bypass a character's safeguards, and handle reports you submit about AI replies.
• Send notifications — deliver push notifications where you have consented.
• Diagnose crashes and errors — use technical diagnostics to maintain app reliability and investigate failures.
• Measure acquisition and product activation — understand which install sources lead to onboarding, dialogue practice and subscriptions, using first-party product events without conversation text.
• Respond to website reports and support requests — investigate the issue, prevent duplicate or recurring problems, and contact you when you provide an email address.
• Deliver a friend-requested invitation — send the initial invitation and limited reminders, show their technical outcome to the inviter, attribute a later registration when the same normalized email is used, and honor a recipient's opt-out. Receiving an invitation does not create an account.

Legal basis — your consent. Processing is based on the consent you give by using the app and granting the relevant permissions (camera, microphone, speech recognition, notifications). You can withdraw consent at any time (see Section 6 and Section 7). Some processing is also necessary to provide the service you request.

4. Sharing with third parties (processors)

To run the app we use third-party providers that process data on our behalf. Your conversation content leaves your device and is processed by these services:

We do not sell your personal data. Sharing is limited to the processors above and to cases required by law.

Where your data is hosted and international transfers

The backend application and the primary database are hosted on DigitalOcean in London, United Kingdom (LON1 region).

Some processors operate on their own infrastructure, which may be located in the United States. In particular, Firebase (Google) and OpenAI process data on Google's and OpenAI's own infrastructure, which may be located in the United States. Where data is transferred internationally, such transfers rely on those providers' standard contractual safeguards.

Website analytics and cookies

The website at liloosafespace.com uses Google Analytics 4 and Google Ads (Google LLC) to understand how visitors use the site and to measure the results of our advertising campaigns. Analytics and advertising cookies and any related storage are disabled by default — they are loaded only after you accept them in the cookie banner shown on your first visit. We run Google Consent Mode: if you decline, the analytics and advertising signals (analytics_storage, ad_storage, ad_user_data, ad_personalization) stay denied and no such cookies are set. You can change your choice later through Cookie settings in the website footer, or clear or block cookies in your browser at any time.

In the mobile app, pseudonymous Google measurement remains disabled until you accept the app's legal documents and continue past the first screen. This is the same on Android and on iOS. It then starts: Firebase Analytics creates a random app-instance identifier and Liloo may send Google Analytics and Google Ads only approved technical event/conversion names (such as registration, dialogue start, activation, trial or purchase) and their timestamps. We do not send an advertising ID, Firebase UID, email, profile data, scenario/persona names or dialogue text for this purpose; ad personalisation remains disabled. You can turn measurement off under About the app on either platform, which prevents future exports. Liloo's first-party product analytics remains separate. Android also reads Google Play Install Referrer once for campaign measurement, and Firebase Crashlytics is used for crash/error diagnostics as disclosed above.

Crisis-safety signals and moderation review

Liloo checks dialogue text in real time for self-harm risk so it can stop the role-play and show a reviewed response and local support resources. This safety check always runs. A critical event is retained for authorised human moderation with the source message, internal account and conversation identifiers, matched safety trigger, direction (user input or AI output), time, system action, review status and moderator notes. It is used only for safety review, incident response and improving the safety filter; it is not exported to Google Analytics or Google Ads and is not used for advertising or personalisation. Critical-event data is removed through the normal account-deletion flow or on a verified privacy request to privacy@liloosafespace.com.

See the separate Consumer Health Data Privacy Policy for the complete categories, sources, processors, retention and rights notice.

5. Data retention

We keep your data only for as long as needed for the purposes above. The schedule below sets out how long each category is retained:

• Account, profile, avatar and device-timezone data — kept while the account is active; erased within 30 days after you delete your account.
• Conversations and messages — kept while the account is active; erased within 30 days after account deletion.
• Account-linked crisis-safety events — kept while needed for safety review, no longer than 90 days, and erased with account deletion or an earlier verified privacy request.
• Dictation audio — current app versions do not store it in Liloo infrastructure; the system speech provider handles it according to the device and provider settings. Earlier supported versions process audio uploaded to Liloo's transcription path ephemerally and delete it immediately after transcription. Recognized text follows the conversation lifecycle above only if you send it.
• Push notification tokens — kept until you disable notifications or delete your account.
• Website reports and support correspondence — kept while the issue is investigated and for as long as reasonably needed to identify duplicate or recurring problems; server log copies follow the 90-day log schedule below.
• Friend invitations — kept with the inviter's account so the inviter can see the result and receive the promised referral bonus. They are deleted when the inviter deletes the account. An invited person can stop later mail from the invitation or ask privacy@liloosafespace.com to delete contact data.
• Purchase and subscription records — retained for up to 3 years after the transaction to meet accounting and tax obligations, even after account deletion, then erased.
• Server logs and diagnostics — up to 90 days. Backups are purged within 30 days.

When you delete your account, your data is removed as described in Section 6, except minimal records we are required to keep by law or to prevent abuse.

6. Account and data deletion

You can delete your account directly in the app: Profile → Delete profile. On confirmation, the app records the deletion request (a to_delete marker) and deletes your Firebase Authentication user. This automatically triggers a server-side cascade cleanup:

• your dialogues and messages are deleted;
• your avatars and their associated storage files (including photos) are deleted;
• associated backend data (PostgreSQL) is purged.

If you cannot use the in-app option or want to confirm deletion, email privacy@liloosafespace.com.

7. Your rights

Depending on your jurisdiction (including under the GDPR) you have the right to:

• access your data and obtain a copy;
• correct inaccurate data;
• delete your data (see Section 6);
• withdraw consent you previously gave (including by revoking camera, microphone, and notification permissions in your device settings);
• restrict or object to processing;
• lodge a complaint with a data protection supervisory authority.

To exercise these rights, contact privacy@liloosafespace.com.

8. Reporting AI content

Liloo deliberately simulates verbal conflict, so AI replies may contain sharp lines and mild profanity by design — that is part of the training scenario. If an AI reply seems genuinely offensive or inappropriate, you can report it directly from within the app. The report reaches us and is used for moderation and to improve our safety systems.

9. Children and eligibility

You must be at least 17 years old to use Liloo. The app is rated 17+ (mature content) and is not directed to children. It contains simulated conflict content with mature, mild-profanity dialogue and is intended for an adult audience. If you believe a person under 17 has provided us with their data, email privacy@liloosafespace.com and we will delete it.

10. Security

All network traffic between the app and our services is encrypted in transit using HTTPS/TLS. Firestore access is governed by per-user, owner-based security rules, and the backend API uses token-based authentication. Data at rest is protected by the underlying infrastructure of our processors (Google Firebase and DigitalOcean).

11. Changes to this policy

We may update this Policy. For material changes we will update the date at the top of this page and, where appropriate, notify you in the app.

FOP Rudenko Yevheniia Yevhenivna (individual entrepreneur, Ukraine) · privacy@liloosafespace.com · Last updated 2026-09-02