Biometric Data Retention and Destruction Policy

This policy explains how Luvu, Inc. (“Luvu,” “we,” “us,” “our”) collects, stores, retains, and permanently destroys biometric identifiers and biometric information through TinyStage, Improv Arena, and related voice-game services that allow users to submit voice recordings, earn coins, and redeem eligible rewards. It is our publicly available written policy governing the retention schedule and destruction guidelines for such data. This policy supplements our Privacy Policy; capitalized terms not defined here have the meanings given in the Privacy Policy.

1. Purpose and Scope

This policy explains how Luvu collects, stores, retains, and permanently destroys biometric identifiers and biometric information through the Service. It is our publicly available written policy governing the retention schedule and destruction guidelines for such data.

2. What This Policy Covers

This policy applies to “biometric identifiers” and “biometric information” as those terms are used under applicable biometric privacy laws. For Luvu, this includes voiceprints; voice recordings or clips; derived acoustic features; speaker embeddings, templates, or other mathematical representations of a speaker; self-reported age and gender; rough or city-level location; optional labels; metadata; user-generated content and input data; inferences; and any voice data that is used, or is reasonably capable of being used, to identify a user. Raw voice recordings are the original audio clips submitted by users, including eligible data producers in the United States, Japan, Mexico, the United Kingdom, Switzerland, the European Economic Area, and other jurisdictions where the voice-data program is made available. Derived biometric templates are embeddings, feature vectors, acoustic measurements, labels, or other data derived from raw recordings that may identify or help identify a speaker. This policy does not apply to information that has been de-identified or aggregated so that it can no longer reasonably be associated with an individual, and does not cover other players or reviewers who only rate or label recordings and do not submit their own voice recordings to Luvu.

3. Consent

We collect and store biometric identifiers and biometric information only after providing notice and obtaining the individual’s consent. Luvu’s onboarding currently requests separate consent for (1) model training, (2) synthetic voice and digital replica use, and (3) AI Partner licensing or sale, in addition to acceptance of our Terms of Service and Privacy Policy. Where we license or sell such data to third-party AI research labs and commercial partners (“AI Partners”), we do so only as disclosed in our Privacy Policy and Terms of Service and, where required, with the individual’s consent, and subject to the individual’s right to opt out or request deletion before licensing or sale. Withdrawing consent stops future collection, licensing, sale, or transfer where reasonably possible, but does not affect processing that occurred before withdrawal or data already licensed, sold, transferred, or incorporated into trained models, model weights, embeddings, synthetic outputs, derivative voices, aggregate statistics, or other downstream model effects. Users under 18 are blocked from contributing voice data based on self-reported age.

4. Retention Schedule

We retain biometric identifiers and biometric information, including both raw recordings and derived biometric templates, only as long as necessary to fulfill the initial purpose for which they were collected, including voice-game operation, quality scoring, reward administration, AI Partner licensing or sale where permitted, model training, voice cloning, voice synthesis, digital replicas, and creation of derivative, synthetic, or cloned voice systems. We permanently destroy such data on the earliest of: (a) the date the initial purpose for collecting the data has been satisfied; (b) three years after the individual’s last interaction with us; or (c) any earlier date required by law or by a valid deletion or withdrawal-of-consent request, subject to legal exceptions and the post-licensing and post-sale limits described below. We do not retain biometric data indefinitely.

5. Destruction Guidelines

When the retention period ends, we permanently and irreversibly destroy biometric identifiers and biometric information using industry-standard methods, including secure deletion of raw recordings, derived acoustic features, speaker embeddings, templates, labels linked to a user or recording, and associated database records; cryptographic erasure or overwriting of storage where appropriate; deletion from active systems; and scheduled deletion or expiration from backups in the ordinary backup cycle. We require service providers, vendors, and, where applicable, AI Partners to delete or destroy biometric data in their possession or control on the same schedule, except to the extent retention is required by law, the data has been de-identified, the data was already licensed, sold, or transferred subject to the limits described below, or deletion from trained models, model weights, embeddings, synthetic outputs, derivative voices, aggregate statistics, or other downstream model effects is not technically feasible.

6. Data Transferred to AI Partners

Luvu may license or sell voice recordings and derived voice data to AI Partners where disclosed and consented to, and does not transfer ownership of Luvu datasets except as expressly stated in a separate agreement. AI Partners may use the data for research, model training, voice cloning, voice synthesis, digital replicas, and derivative, synthetic, or cloned voice systems. Voice data licensed or sold to AI Partners may include raw recordings; voiceprints and derived acoustic features where applicable; speaker embeddings or templates; self-reported age and gender; rough or city-level location, including country-level geography where applicable; optional human-applied labels such as voice quality or style descriptors; metadata; user-generated content and input data; and inferences. Users may request deletion before their voice data is licensed or sold to an AI Partner. After licensing or sale, Luvu will forward deletion requests covering raw clips and associated biometric data to the relevant AI Partner where required by law or contract, and will require the AI Partner to delete data it can reasonably identify and control. However, Luvu may not be able to extract, untrain, or delete data once it has been incorporated into trained models, model weights, embeddings, synthetic outputs, derivative voices, aggregate statistics, or other downstream model effects, and this policy does not promise deletion where extraction is not technically feasible.

7. Illinois Residents

Unless and until Luvu implements a separate Illinois biometric compliance program, Luvu does not offer voice-contribution, coin-reward, cash-out, biometric collection or processing, or AI Partner licensing or sale features to Illinois residents or users located in Illinois. If we determine that an individual is located in Illinois or is an Illinois resident, we will not enroll that individual in these features and will block participation in the biometric voice-data program. Users must not use a VPN, false location, or other workaround to access those features from Illinois. For clarity, this Illinois restriction does not exclude eligible data producers located in Japan, Mexico, or other jurisdictions where the voice-data program is made available, subject to applicable law.

8. Security

We store, transmit, and protect biometric identifiers and biometric information using a reasonable standard of care, and in a manner that is the same as or more protective than the manner in which we store, transmit, and protect other confidential and sensitive information.

9. No Sale, Lease, Trade, or Profit Except as Disclosed

We do not sell, lease, trade, license, or otherwise profit from biometric identifiers or biometric information except as disclosed in our Privacy Policy and Terms of Service, described in this policy, consented to where required, and permitted by applicable law.

10. Changes

We may update this policy from time to time. The “Last Updated” date reflects the most recent change.

11. Contact

Luvu, Inc.
114 South Negley Ave, Apt 1A
Pittsburgh, PA 15206
support@luvufit.com