Privacy Policy

Privacy Policy and Terms of Data Processing

Last Updated & Effective Date: 27/07/2026

Welcome to Lulu (hereinafter referred to as “Lulu”, “Platform”, “Application”, or “App”). Please read this comprehensive Privacy Policy carefully before using our services.

LEGAL ENTITY & ACCEPTANCE OF TERMS

The Lulu mobile application, its corresponding website, and all associated services are exclusively owned, developed, operated, and provided to you by Kroxiva Technologies, a registered sole proprietorship legally owned and represented by Rakesh Kumar (hereinafter referred to as the “Company”, “we”, “us”, or “our”).

For all legal, regulatory, taxation, and payment-processing purposes, any financial transactions, user agreements, or digital engagements on the Platform are executed directly with Kroxiva Technologies. By downloading, registering on, accessing, or using Lulu, you acknowledge that you have read, comprehensively understood, and unequivocally agree to be bound by this Privacy Policy. If you do not agree with any provision of this document, you must immediately discontinue your use of the Platform and uninstall the Application.

1. CONSENT MECHANISM & DATA PROCESSING APPLICABILITY

We process your personal data strictly based on your explicit consent, which is obtained through clear in-app affirmative actions (e.g., checking a box or clicking “Continue” after reviewing this policy).

  • Withdrawal of Consent: You retain the fundamental right to withdraw your consent at any time by modifying your device permissions or writing to our Grievance Officer.
  • Consequences of Withdrawal: Withdrawing consent will halt further data processing for that specific purpose. However, it will not affect the lawfulness of processing based on consent before its withdrawal. Disabling essential permissions may render certain core features of the App unusable.

2. COMPREHENSIVE INFORMATION WE COLLECT

To deliver a secure, personalized, and seamless experience, we collect categorized data actively provided by you and passively collected through automated technologies.

A. Information You Provide Directly:

  • Identity & Account Data: Mobile phone number (mandatory for secure OTP login, verification, and account recovery), Display Name/Alias, Date of Birth (mandatory to ensure you are 18+ and for age-based matching).
  • Profile & Matchmaking Data: Gender, dating/social preferences, interests, bio descriptions, spoken languages, and profile category (“position”).
  • User-Generated Content: Photographs, videos, audio/voice notes, chat messages, and multimedia shared within private interactions or public profile sections, including view-once (self-destructing) media.
  • Customer Support Data: Information, screenshots, and contact details shared when communicating with our helpdesk for troubleshooting or dispute resolution.

B. Location Data:

  • Approximate Location: We may collect non-precise location data (e.g., city, state, country derived from your IP address or network provider) for basic functionality and fraud prevention.
  • Precise GPS Location: Lulu does not request or collect your device’s precise GPS coordinates, and does not use GPS-based proximity matching at this time.

C. Automated Behavioral, Technical & Interaction Data:

  • Device & Network Data: Internet Protocol (IP) address, device manufacturer, hardware model, operating system version, unique device identifiers (Android ID, Advertising ID), and network carrier.
  • Usage & Telemetry Data: Session durations, timestamps, clickstream data, feature utilization rates, and crash logs.
  • Interaction Logs: Records of matches, profile views, calls (voice/video), random-connect sessions, message delivery/read status, user blocks, and misconduct reports. This is critical for our safety algorithms.

D. Permissions Requiring Explicit Prompting:

We will request runtime permissions to access your device’s Camera (for live photos/video calls), Microphone (for voice notes/calls), and Photos/Media Gallery (for uploading media).

3. DATA COLLECTION FROM THIRD-PARTY SOURCES

To maintain robust security and smooth operations, we integrate with verified external partners and may receive the following:

  • Payment Gateways: Transaction IDs, payment success/failure statuses, subscription tiers, and billing timestamps.
  • Identity Verification Services: Output from third-party systems used to detect bots, verify real users, and prevent catfishing.
  • Cloud & Analytics Services: Aggregated usage reports and server interaction logs.

4. EXHAUSTIVE PURPOSE OF DATA UTILIZATION

Kroxiva Technologies processes your data under the legal basis of “Legitimate Business Interest,” “Performance of a Contract,” and “Legal Compliance” for the following exhaustive purposes:

  1. Service Provisioning: Creating your account, authenticating logins, calculating matchmaking algorithms, and routing chat/call traffic.
  2. Platform Security & Moderation: Detecting and banning fraudulent accounts, scammers, and bots. Scanning profiles and reports for Terms of Service violations.
  3. Financial Operations: Fulfilling premium subscriptions, processing refunds, and maintaining accounting records for tax compliance.
  4. Product Improvement: Analyzing user behavior to debug the app, optimize server loads, and design new features.
  5. Legal & Regulatory Obligations: Responding to valid legal requests from law enforcement and complying with data localization or taxation laws.

We categorically declare that we DO NOT sell, rent, or trade your personal data to data brokers or any third parties for their independent marketing purposes.

5. DATA STORAGE, HOSTING, AND ENCRYPTION SECURITY

  • Infrastructure: Your data is housed on secure cloud infrastructure. Data pertaining to users within specific jurisdictions (such as India) is localized and stored on servers geographically located within that jurisdiction to comply with local laws (e.g., DPDP Act).
  • Encryption Protocols: All data transmitted between your device and our servers is encrypted using TLS/SSL protocols. Highly sensitive data at rest (stored on databases) is secured using industry-standard encryption.
  • Access Controls: We employ the “Principle of Least Privilege.” Only authorized personnel at Kroxiva Technologies who require access to perform their operational duties can access backend systems.
  • Breach Protocol: In the rare event of a data breach, we possess an incident response plan to quickly contain the threat and will notify affected users and regulatory authorities within the legally mandated timelines.

6. STRICT DATA RETENTION & DELETION POLICIES

  • Active Accounts: Data is kept to provide seamless service.
  • Account Deletion: When you request account deletion, your profile instantly becomes invisible to other users. We will initiate the permanent erasure or irreversible anonymization of your profile data within 30 to 90 days.
  • Legal Holds (Exceptions): We are legally obligated to retain specific records even after account deletion, including:
    • Financial transaction logs (retained for up to 7 years for taxation and audit purposes).
    • IP logs, blocked account details, and chat records associated with reported abuse or fraud.

7. PAYMENT PROCESSING & GATEWAY COMPLIANCE

  • No Direct Storage: Kroxiva Technologies does not directly collect, process, or store your sensitive financial data (such as full Credit/Debit Card numbers, CVV, or UPI PINs) on our servers.
  • PCI-DSS Compliance: Payments are securely routed through our authorized, PCI-DSS compliant third-party payment gateways (including Razorpay, PhonePe, and Cashfree), and, for digital subscription unlocks on Android, through Google Play’s Billing System.
  • Transaction Records: We solely retain non-sensitive transaction metadata (e.g., Transaction ID, Date, Amount, Subscription Status) necessary to activate your premium services and resolve billing disputes.

8. ARTIFICIAL INTELLIGENCE & AUTOMATED PROCESSING

Lulu actively deploys Artificial Intelligence (AI), Machine Learning (ML), and automated algorithms to ensure user safety and quality interactions.

  • Moderation: AI systems automatically scan uploaded profile photos and messages to detect nudity, explicit content, spam, or fake images, flagging them for removal.
  • Matchmaking: Automated systems process your preferences and app behavior to generate personalized user recommendations.
  • AI-Assisted Conversations: Some replies you receive — particularly from admin-managed or Discover-feed profiles — may be generated or assisted by AI rather than a real person in real time. Message content exchanged in such conversations may be processed by our AI service providers solely to generate a relevant response.
  • Spam Detection: Algorithms analyze messaging patterns to swiftly detect and ban malicious accounts distributing spam or phishing links.

9. SHARING & DISCLOSURE TO THIRD PARTIES

We strictly share data on a “need-to-know” basis with the following entities:

  • Service Providers: Technical partners providing SMS/OTP delivery, cloud hosting, database, push notifications (Firebase Cloud Messaging), crash reporting, and analytics. These entities process data strictly under our instructions.
  • Advertising Partners: We work with Google AdMob and Meta (Facebook) Audience Network / Facebook App Events, to show advertisements and measure ad performance within the App. These partners may collect and process your device’s Advertising ID and interaction data to serve personalized ads based on your interests.

Law Enforcement & Government: We will disclose user data if legally compelled by a court order, subpoena, or lawful request by government agencies, or to protect the vital interests, safety, and physical security of any person.

  • Business Transfers: In the event of an acquisition, merger, bankruptcy, or sale of assets involving Kroxiva Technologies, user data will be securely transferred to the acquiring entity subject to the continuity of these privacy protections.
  • Advertising and Data Processing: To facilitate personalized ads, we share certain non-sensitive data, including your device’s Advertising ID, hardware model, and interaction logs, with Google AdMob and Meta Audience Network. You can opt-out of such interest-based advertising at any time by adjusting your device’s advertising settings (e.g., Settings > Google > Ads > Delete Advertising ID on Android, or the App Tracking Transparency prompt on iOS).

Third-Party Privacy Policies:

10. YOUR PRIVACY RIGHTS & CONTROLS

  • Right to Access: You can request a summary of the personal data we hold about you.
  • Right to Rectification: You can correct or update inaccurate profile information directly within the App.
  • Right to Erasure (Right to be Forgotten): You can request the deletion of your account and associated personal data via the App settings or by emailing support.
  • Right to Restrict/Withdraw: You may revoke permissions for camera and microphone at the device operating system level.
  • Right to Opt-out of Ads: You can limit or stop personalized advertising by resetting or deleting your Advertising ID in your device settings.

11. USER CONTENT OWNERSHIP & LICENSE

You retain ultimate ownership of the content (photos, text, messages) you upload to Lulu. However, by posting such content, you grant Kroxiva Technologies a worldwide, royalty-free, operational license to host, store, display, and process this content to facilitate the App’s services. We reserve the unequivocal right to delete any user content that violates our Terms of Service or local laws without prior notice.

12. STRICT AGE RESTRICTIONS (CHILDREN’S PRIVACY)

The Lulu Platform is strictly intended for adult users who are 18 years of age or older. We do not knowingly solicit, collect, or process personal data from minors. If we detect or are informed that an underage individual has bypassed our age-gates, we will take immediate action to permanently terminate the account and purge all associated data from our servers.

13. COMMUNICATIONS & PROMOTIONS

By registering on the Platform, you consent to receive essential service communications (OTPs, account security alerts, billing invoices) and promotional updates regarding new features or offers, via SMS, Email, and Push Notifications. You have the freedom to opt-out of promotional communications via app settings, though critical legal and security alerts cannot be disabled.

14. POLICY UPDATES & MODIFICATIONS

Kroxiva Technologies reserves the right to amend, update, or modify this Privacy Policy at our sole discretion to reflect technological advancements, new features, or changes in legal regulations. Significant changes will be communicated via an in-app notification or email. Your continued use of the Platform following such modifications constitutes your formal acceptance of the revised Privacy Policy.

15. GRIEVANCE REDRESSAL MECHANISM & CONTACT INFO

Grievance Officer: Himanshu Himanshu Email: officialgogoapp@gmail.com

Kroxiva Technologies First floor, Vill Kasrak, Front of primary school no 1, Block Khudaganj, Dist Shahjahanpur, Uttar Pradesh, 242301, India

General Support: For standard account help, billing inquiries, or technical support: Email: help@gogodatings.com

Registered Office Address: Kroxiva Technologies First floor, Vill Kasrak, Front of primary school no 1, Block Khudaganj, Dist Shahjahanpur, Uttar Pradesh, 242301, India

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