Privacy Policy

What this policy covers

This policy applies to information collected in the Luli app and in email, text, and other electronic communications sent through or in connection with it. It does not apply to other apps or websites, including third-party sites you may reach through Luli, or to information collected by any third party — those third parties have their own privacy policies. If you do not want your information collected or used as described here, you can uninstall Luli from your device at any time.

Information you provide

When you use Luli, you may choose to provide any of the following, referred to together as your User Data:

• your baby's name or preferred means of address
• your baby's birthday
• your email address
• your child's nap schedule
• your child's feeding schedule
• information about your child's hygiene and activity
• personal notes, which could contain information that identifies you

By default, your User Data is stored only on the device you use — we cannot access it unless you choose to back it up. If you turn on backup, your User Data is uploaded to Cloud Firestore and encrypted; a limited number of our employees can access it. Cloud Firestore's own data processing and security terms are at firebase.google.com/support/privacy. We ask for a password to protect that backup, and an email address so you can reset the password if you forget it. If you give us a name or preferred means of address, we use it only to personalize your in-app experience. Beyond these limited uses, your User Data is used only to run the app for you.

Voluntary feedback

You can send us feedback by rating or reviewing Luli on the app stores, or by email. App store reviews are public and visible to anyone. We take feedback seriously and often act on it. Feedback sent by email is handled by our support staff and is not shared with third parties.

Analytics data

Our app tracks and sends us anonymous Analytics Data about how Luli is used, consisting of:

• a device identifier that lets us group issues from the same device
• crash logs, so we can investigate application failures
• app interaction signals and event data, showing how features are used

We use Analytics Data to fix bugs, improve the app, and evaluate features. It cannot be traced back to you. We process it using Google Analytics, Google Analytics for Firebase, and Microsoft App Center, and do not otherwise share it.

Advertising data

Advertising. Luli does not display advertising. The advertising provisions in this policy apply to other apps published by SimpleInnovation and not to Luli; Luli does not share data with advertising partners.

Luli is in part supported by advertising. Unless you opt out, we may send our advertising partners a standard advertising identifier collected from your device — a random ID generated by your phone's operating system, not tied to your name or contact details. Advertising identifiers are typically stable over time, so a third party could, in theory, combine one with location or other app data to build inferences about you. Both iOS and Android let you reset or disable your advertising identifier at any time; if you disable it, we will not send it to our advertising partners.

We send only the advertising identifier itself, with no other personal information attached.

Purchase data

If you buy a subscription or other in-app item, the Apple App Store or Google Play processes that transaction, not us. We have no access to your payment details and see only a limited summary the app store shares with us: an order ID, price, the date and time of purchase, and sometimes a ZIP code. We use this only to help process refunds when appropriate, and do not share it with third parties.

How information may be shared beyond the uses above

If required by a valid court order, law, or legal process, we may use your Personal Information to comply. If Luli is involved in a merger, acquisition, or sale of assets, your Personal Information and User Data could transfer to the buyer. Where the law requires it, we will try to notify you — on our website, in the app, or by email if we have one for you — and we will instruct the recipient to keep honoring this policy. We cannot guarantee that a third party will follow that instruction after a transfer, and any new information you provide afterward would be covered by that party's own policy.

Third-party services we use

We do not control these partners' tracking technologies or how they use them. If you have questions about a specific ad, check the partner's own policy — this policy does not extend to them.

Membership in self-regulatory frameworks

We are members of the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Japan Interactive Advertising Association, and follow their cross-industry self-regulatory principles for online behavioral advertising.

How we protect your information

We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your data. That said, transmitting information over the internet and mobile networks is never completely secure — we cannot guarantee the security of personal information sent through Luli, and any transmission is at your own risk. We are not responsible for anyone circumventing the privacy settings or security measures we provide.

Your choices about your information

• Advertising identifier: reset or disable it at any time from your device's settings — depending on your operating system, this is Apple's Ad Tracking (AppTrackingTransparency) or Google's advertising ID setting. Resetting it prevents advertisers from linking your past activity to your device going forward.
• Other tracking technologies: your device may let you disable cookies or similar technologies. We do not respond to browser or device "do not track" signals ourselves, though some of our advertising partners may.
• Targeted advertising by networks: we do not control how third parties use your information for interest-based ads, but many let you opt out directly. Look for an AdChoices icon or link near an ad, or use one of these options:

• if the advertiser is a member of the Digital Advertising Alliance: install and use the AppChoices app
• if the advertiser is a member of the European Interactive Digital Advertising Alliance: opt out at youronlinechoices.eu
• for Google Ads specifically: see Google Ads Help — Opt Out

Uninstalling the app

You can stop all collection of information by Luli by uninstalling it, using your device's or app store's standard uninstall process.

Accessing, correcting, and deleting your information

You can ask to access, update, change, or delete your Personal Information through our Contact page or by emailing babysleep@simpleinnovation.us. We aim to respond within one month, free of charge. With any such request, we may verify your identity or ask for more information, decline a request that falls under an exemption in applicable data protection law, and charge a reasonable fee for repetitive, unfounded, or excessive requests.

Your California privacy rights

We do not sell or share your User Data outright, but sending an advertising identifier to our partners may count as a "sale" of Personal Information under California law. As described above, you can stop this at any time by resetting or disabling your device's advertising identifier.

California residents may also ask us, via babysleep@simpleinnovation.us or our Contact page, to:

• disclose, for the past 12 months, the categories of Personal Information we collected and their sources, why we collected it, which categories of third parties we disclosed it to and what we disclosed, and the specific pieces we hold on you
• delete the Personal Information we collected from you
• correct the Personal Information we collected from you

You are entitled to a copy of this information in a standardized, non-individualized format, and you will not be discriminated against for exercising these rights.

In the last 12 months, we have collected these categories of Personal Information: personal unique identifiers (a name or preferred means of address, if provided); personal information such as an email address, a ZIP code from an app store, or health-related notes you choose to log; and biometric information you choose to log, such as medicines, temperatures, or measurements. We have shared Personal Information for a business purpose when you chose cloud backup (sent to Google Cloud) and when we send anonymized Analytics Data to Google Analytics. Unless you opted out, we have also provided your device's advertising identifier to our advertising partners, which may be considered a "sale" of Personal Information.

If you are located in the European Union

To contact our Data Protection Officer, email babysleep@simpleinnovation.us with the subject line "ATTN: DPO." Where our advertising SDKs collect non-personally-identifying data for our US advertising partners, the legal basis is your consent (GDPR Art. 6(1)(a)); you can withdraw it at any time via the opt-out mechanisms above, in-app settings, or by uninstalling Luli. Where you ask us to back up your User Data to Google Cloud, the legal basis is performance of that request (GDPR Art. 6(1)(b)). Providing your information is never required by law or contract; without it, we cannot personalize ads or measure how you use Luli. You have the right to access, rectify, or erase your personal data, to restrict its processing, to data portability, and to lodge a complaint with a supervisory authority.

Changes to this policy

We may update this policy at any time. When we do, the updated policy is made available from within Luli, and it takes effect once posted. The date at the top of this page shows when it was last revised — check back periodically for changes.

Contact us

Questions or concerns about this policy can go to babysleep@simpleinnovation.us.

AppManage Group #1, LLC 15127 NE 24th Street, Ste 132 Redmond, WA 98052