Privacy Policy

This Privacy Policy explains how Luvu, Inc. (“we,” “us” and “our”) handles personal information when you visit our websites, use TinyStage (iOS), Improv Arena (web), or our related products and services, or otherwise interact with us. By using our services, you agree to the practices described here. If you do not agree, do not use our services. This policy works alongside our Terms of Service.

This policy applies to information we collect through our marketing site, TinyStage, Improv Arena, and any other channel where we collect data directly from you. It does not apply to third-party sites or services we do not control. This Privacy Policy does not apply where Luvu, Inc. acts as a data processor and processes personal information on behalf of business customers, for example if your employer has provisioned your account; in that case our customer agreement and data processing agreement govern.

California Notice at Collection. We collect the categories of personal information described in the What We Collect section for the purposes described in the Why We Collect It section. For details about the personal information we share for cross-context behavioral advertising and how to opt out, see the Sale and Sharing of Personal Information section. For the full list of your California rights and how to exercise them, see the State-Specific Rights section below.

1. Who We Are

Luvu, Inc. is a company incorporated in Delaware, with its principal place of business at 114 South Negley Ave, Apt 1A, Pittsburgh, PA 15206. Questions about this policy or your data can be sent to support@luvufit.com.

2. What We Collect

We collect the following categories of personal information, using the categories defined under California law:

• Identifiers. Name, email address, IP address.
• Customer records. Billing address, payment information processed by our payment provider.
• Usage data. How you interact with our product and site, including voice games played, recordings submitted, coins earned and redeemed, quality scores, features used, pages viewed, actions taken, and approximate location derived from IP address.
• Geolocation. Approximate location based on IP address. We do not collect precise device location.
• Inferences. Information we derive from the above to understand how customers use our services.
• Audio or visual information. Voice recordings and other audio you submit through our services, support call recordings, profile photos, or other media you provide or upload.
• Protected classifications. Self-reported age, gender, and similar demographic information you choose to provide. Users who self-report that they are under 18 are blocked from using the voice-contribution and coin-reward features.
• Biometric information. Where applicable, voiceprints, voice data, derived acoustic features, and other voice identifiers that may be used to identify you or to create, train, evaluate, or improve voice, speech, synthetic voice, digital replica, or voice-cloning systems.
• User-generated content and input data. Voice prompts, spoken responses, comments, messages, posts, photos, images, videos, documents, works of authorship, optional labels or annotations you provide, and other content you create, upload, transmit, or store on our services, together with associated metadata such as how, when, and by whom content was created or edited.

We also collect the following category of sensitive personal information, as defined by California law: biometric information, specifically voiceprints and derived acoustic features processed to identify you. We use this information only for the purposes described in this policy and as permitted by law. If we use sensitive personal information beyond the purposes necessary to provide the services you request, you can limit that use by contacting us at support@luvufit.com.

Biometric Information Notice. When you contribute voice recordings, we collect and store biometric identifiers and biometric information (such as voiceprints and derived acoustic features) in order to develop, train, and provide the features described in this policy and, where you have given consent and have not withdrawn it, to license or sell such data to AI Partners. AI Partners may use licensed data for model training, voice cloning, voice synthesis, digital replicas, and creating derivative or synthetic voices. We obtain your consent before collecting this information, store and protect it using a reasonable standard of care, and destroy it in accordance with the Retention section. We do not sell, lease, trade, or otherwise profit from your biometric information except as disclosed in this policy and as permitted by applicable law. Full details are in our Biometric Data Retention and Destruction Policy.

Illinois Residents. Unless and until Luvu implements a separate Illinois biometric compliance program, Luvu does not offer the voice-contribution, coin-reward, cash-out, biometric collection or processing, or AI Partner licensing features to Illinois residents or users located in Illinois. If we determine that you are located in Illinois or are an Illinois resident, we will not enroll you in these features and may disable them for your account.

3. How We Collect It

We collect personal information three ways:

• Directly from you. When you create an account, self-report your age or gender, contribute voice recordings, add optional labels, fill out a form, contact support, or otherwise interact with us.
• Automatically. When you visit our site or use our product, we automatically collect technical information through cookies and similar technologies.
• From third parties. Our payment processor, analytics providers, and similar service providers send us information related to your use of our services. We may also receive information about you from other sources, such as public sources (for example, public records or social media platforms), data providers, and marketing or referral partners.

4. Mobile App Permissions

Our mobile app may request permissions for features such as your microphone, camera, photos, location, and notifications. These permissions are optional, but microphone access is required to record voice contributions. The app will function without optional permissions, although certain features may be unavailable. You can change these permissions at any time in your device settings.

5. Why We Collect It

We use personal information to:

• Provide, maintain, and improve TinyStage, Improv Arena, and our related products and services.
• Authenticate accounts and prevent fraud and abuse.
• Process payments and bill customers.
• Communicate with you about your account, our services, and product updates.
• Respond to your inquiries and provide support.
• Understand how customers use our services, run automated quality scoring, support human review and labeling, and improve our services.
• Comply with legal obligations, enforce our terms, and protect our rights.

6. Aggregated and De-Identified Data

We may create aggregated or de-identified data from personal information by removing identifiers and combining records so that you cannot reasonably be re-identified. Aggregated and de-identified data is not personal information. We may use and disclose it for any lawful purpose, including improving our products and publishing usage statistics. We publicly commit to maintain and use this data only in de-identified form and not to attempt to re-identify it, and we contractually require the same of any recipients.

7. Who We Share It With

We share personal information with the following categories of recipients:

• Affiliates. Our parent, subsidiaries, and other entities under common control with us, for the purposes described in this policy.
• Service providers and sub-processors that operate our infrastructure, payments, analytics, communications, automated quality scoring, human review and labeling, and similar functions. We bind them by written agreements that limit their use of personal information to providing services to us. A current list of our sub-processors is available on request at support@luvufit.com.
• Professional advisors including auditors, lawyers, and accountants.
• Government authorities when required by law, subpoena, or other legal process.
• AI Partners. AI research labs and commercial AI partners that license or buy voice recordings, voiceprints, derived acoustic features, age, gender, rough location, optional labels, and related metadata for model training, voice cloning, voice synthesis, digital replica, and derivative or synthetic voice development. Luvu retains ownership of collected voice data, and AI Partners receive licenses or other rights described in their agreements with us.
• Other users and the public. If you post content publicly through our service (such as profile information, comments, or shared posts), that content can be viewed, copied, or stored by other users and the public. We are not responsible for how third parties use content that you have made public.
• In a business transaction such as a merger, acquisition, or sale of assets, in which case the acquirer will be subject to this policy or one materially similar.

If you choose to log into our service using a third-party account (for example, Google, Microsoft, or another single sign-on provider), we receive information from that provider as permitted by your settings with the provider, including your name, email address, and profile identifier. The provider’s use of any data you share with it remains governed by the provider’s privacy policy, not ours. If you connect or authorize a third-party service from within our product, including PayPal, Venmo, gift card providers, or similar payout partners, we may share information with that service at your direction; that service’s use of the information is governed by its own privacy policy, not ours.

We do not share personal information with third parties for their own direct-marketing purposes. If you are a business customer and require a Data Processing Addendum, our standard DPA is available on request at support@luvufit.com.

8. Sale and Sharing of Personal Information

We “sell” personal information (disclose it for monetary or other valuable consideration), including when we license voice and related data to AI Partners. The categories we sell or license are: audio or visual information, including voice recordings; biometric information where applicable, including voiceprints and derived acoustic features; protected classifications and demographic information you provide, including self-reported age and gender; geolocation information, including rough or city-level location; user-generated content and input data, including optional labels, metadata, and content you provide; and inferences. We also “share” personal information for cross-context behavioral advertising as that term is defined under California law. This includes our use of third-party advertising and tracking technologies such as Google Ads, Meta Pixel (Facebook), Twitter (X) Pixel, and TikTok Pixel. The categories of personal information we share for that purpose are: device identifiers and advertising IDs. We do not knowingly sell or share the personal information of consumers under 16, and users who self-report that they are under 18 are blocked from the voice-contribution and coin-reward features. You can opt out of both the sale and the sharing of your personal information by visiting Do Not Sell or Share My Personal Information, by sending a Global Privacy Control signal through your browser, by changing the relevant account setting, or by contacting us at support@luvufit.com. If you opt out, you can keep using the Service, but coin earning pauses because Rewards are consideration for the data you share.

9. AI and Machine Learning

We use your recordings and the data derived from them to operate and improve the Service, run automated quality scoring, support human labeling, and to develop and train our own artificial intelligence and machine learning features, if you have given the applicable consent and have not withdrawn it. During onboarding, we currently ask for separate consents for (1) model training, (2) synthetic voice and digital replica use, and (3) AI Partner licensing or sale, in addition to your acceptance of our Terms of Service and Privacy Policy. You can withdraw consent at any time by contacting us at support@luvufit.com or by changing the relevant setting in your account. Withdrawal stops future collection and future licensing where we can reasonably do so, but it does not affect processing that occurred before withdrawal or data already licensed to an AI Partner.

We also license and sell your voice recordings and derived voice data, which may include biometric identifiers such as voiceprints and derived acoustic features, plus self-reported age, gender, rough or city-level location, optional labels, related metadata, user-generated content and input data, and inferences, to third-party AI research labs and commercial partners (“AI Partners”) for their own model training and development, including automatic speech recognition, text-to-speech, voice cloning, voice synthesis, digital replicas, and derivative, synthetic, or cloned voice systems. Before we transfer data to an AI Partner we de-identify it where feasible, and AI Partners agree in writing not to re-identify you and not to redistribute raw licensed data except as permitted in their agreements with us. See the Sale and Sharing of Personal Information and Your Rights sections for how to opt out. We may also use aggregated and de-identified data, which is not personal information, to evaluate and improve our product features.

10. Cookies and Similar Technologies

We use cookies and similar technologies to operate our site and product, remember your preferences, understand usage, and measure the effectiveness of our communications. These fall into four types: essential cookies required for the site and product to function (such as authentication and security); functional cookies that remember your preferences and settings; analytics cookies that help us understand how our services are used; and advertising cookies that measure the effectiveness of our communications and support the advertising described in the Sale and Sharing of Personal Information section. Disabling non-essential cookies through your browser will not prevent core features from working. You can control cookies through your browser settings. We do not currently respond to “Do Not Track” signals because there is no industry consensus on how to interpret them. We honor opt-out preference signals recognized under applicable law, including the Global Privacy Control (GPC). When we detect such a signal, we treat it as a request to opt out of the sale or sharing of personal information associated with that browser or device.

11. Marketing Communications

You can unsubscribe from marketing emails by using the unsubscribe link in any marketing message or by contacting us at support@luvufit.com. Service emails (about your account, billing, security, or required notices) will continue.

12. Your Rights

Depending on where you live, you may have the right to:

• Access the personal information we hold about you.
• Correct inaccurate personal information.
• Delete your personal information, subject to legal exceptions and the limits described in the Retention section for data already licensed to AI Partners or incorporated into trained models.
• Opt out of the sale or sharing of your personal information for cross-context behavioral advertising.
• Opt out of certain automated decision-making, where applicable. We use automated quality scoring for voice contributions; no formal appeal process is currently offered for quality scores unless required by law.
• Receive a portable copy of your personal information.
• Be free from discrimination for exercising these rights.
• Withdraw consent to the processing of sensitive personal information, model training, synthetic voice use, or AI Partner licensing, where consent is the basis for processing.

13. How to Exercise Your Rights

To exercise any of these rights, email us at support@luvufit.com. We will verify your identity before responding. We will respond within forty-five days, with one extension permitted by law if we need more time. We will tell you if we cannot fulfill the request, and why. You can use an authorized agent. Provide written permission from you and identification for the agent.

14. Retention; Deletion Requests; Limits After Licensing

We keep personal information for as long as we need it for the purposes described in this policy. The actual period depends on the type of information, the reason we collected it, applicable legal obligations (such as tax and accounting), and your relationship with us. When we no longer need it, we delete or anonymize it. If you close your account, we delete or anonymize information associated with the account promptly, subject to the exceptions in this section (records kept for legal, accounting, fraud-prevention, or dispute-resolution reasons). You may request deletion of voice recordings and related data before those recordings are licensed to an AI Partner. If your data has already been licensed, we will delete the raw clips and related personal information we still control and, where required by applicable law or our agreements, forward your deletion request to the relevant AI Partner for deletion of raw licensed clips it controls. However, once data has been used to train, fine-tune, evaluate, or improve AI models, extraction or deletion from trained models, model weights, embeddings, synthetic outputs, derivative voices, or aggregate statistics may not be technically possible. We permanently destroy biometric identifiers and biometric information no later than three years after your last interaction with us, or when the initial purpose for collecting them has been satisfied, whichever occurs first, except as otherwise required by law. This commitment is described further in our publicly available Biometric Data Retention and Destruction Policy.

15. Security

We protect personal information using administrative, technical, and physical safeguards reasonable to the type of information and our size, including safeguards for voice recordings, biometric information, and data made available to other players or AI Partners. No system is perfectly secure, and we cannot guarantee that information will never be accessed by unauthorized parties. We will notify you of a breach affecting your personal information as required by law.

16. Children

Our services are not directed to, and we do not knowingly collect personal information from, anyone under 18. Age is self-reported during onboarding, and users who self-report that they are under 18 are blocked. If you believe someone under 18 has given us personal information, contact us at support@luvufit.com and we will delete it.

17. Financial Incentives

We offer a financial incentive in exchange for the collection, retention, and sale of your personal information: coin rewards that can be cashed out through PayPal, Venmo, or gift cards. Material terms: you earn coins by contributing voice recordings and related data, which we may license or sell to AI Partners as described in the Sale and Sharing of Personal Information section; coins are redeemable at 1,000 coins = $1 USD, subject to a minimum cash-out amount we show in the app (currently between $3 and $5 USD). Good-faith value estimate: we calculate the value of your data based on the revenue we reasonably expect to receive from AI Partners for contributed data, less our costs of collection, de-identification, quality scoring, human labeling, and processing, which we currently estimate as the cash value of the redeemable coins you earn, using the redemption rate of 1,000 coins = $1 USD. Participation is voluntary. You opt in by enabling contributions and can withdraw at any time by disabling contributions or contacting us at support@luvufit.com; if you withdraw, coin earning pauses.

18. State-Specific Rights

The following sections describe additional or modified rights for residents of specific US states. Where a state law gives you a right not listed here, we honor it whether or not it is described.

(a) California (CCPA / CPRA)

All rights in the Your Rights and How to Exercise Your Rights sections apply. You also have the right to limit the use of sensitive personal information, and the right to know the specific pieces of personal information we hold about you. You can designate an authorized agent. In the preceding 12 months (or such shorter period as we have been operating), we have collected the categories of personal information listed in the What We Collect section. We have disclosed each of those categories for business purposes to the categories of recipients listed in the Who We Share It With section. We have sold the following categories of personal information: audio or visual information, including voice recordings; biometric information where applicable, including voiceprints and derived acoustic features; protected classifications and demographic information you provide, including self-reported age and gender; geolocation information, including rough or city-level location; user-generated content and input data, including optional labels, metadata, and content you provide; and inferences. We have shared the following categories of personal information for cross-context behavioral advertising: device identifiers and advertising IDs. California residents may have additional rights relating to voice, likeness, digital replica, and synthetic voice uses, including rights to control certain commercial uses of their name, voice, signature, photograph, or likeness. California’s “Shine the Light” law also lets California residents request information about personal information we disclosed to third parties for those third parties’ own direct-marketing purposes; as stated above, we do not share personal information with third parties for their own direct marketing.

(b) Other US States

Residents of US states with comprehensive privacy laws have the rights described in the Your Rights and How to Exercise Your Rights sections, with state-specific differences as required by each state’s law. New York, Tennessee, Texas, and Washington residents may also have state-specific rights or restrictions relating to voice, likeness, biometric identifiers, biometric information, digital replicas, synthetic voices, or commercial use of identity. Where required, we will obtain any additional consent, honor applicable opt-out or deletion rights, restrict uses that are not permitted, or exclude users from affected features.

(c) Nevada

Nevada residents have the right under SB 220 to submit a verified request directing us not to sell their covered personal information to third parties. To submit such a request, contact us at support@luvufit.com with “Nevada Opt-Out” in the subject line.

(d) Appeals

If applicable state privacy law gives you the right to appeal our denial of a privacy request, you may appeal by contacting us at support@luvufit.com with “Appeal” in the subject line. We will respond to your appeal within the time required by law. If your appeal is denied, you may contact your state Attorney General’s office to lodge a complaint. This appeal process applies to privacy-rights requests where required by law; it is not a formal appeal process for automated quality scores, unless applicable law requires one.

19. International Users

We process personal information in the United States. Data producers may be located in a number of countries, including the United States, Japan, Mexico, the United Kingdom, Switzerland, and the European Economic Area. If you access our services from outside the United States, your information will be transferred to and processed in the United States and may be accessed from or processed in other countries where our service providers, reviewers, or AI Partners operate, where data protection laws may differ from those in your country.

(a) Supplemental Notice for Japan Users

If you are located in Japan, Luvu may provide or license voice clips and related data described in this policy to AI Partners, including recipients in the United States and other countries, only with your onboarding consent. You may request disclosure, correction, cessation of use, or cessation of third-party provision of retained personal data by contacting support@luvufit.com, subject to applicable law. You may also contact Japan’s Personal Information Protection Commission where applicable.

(b) Supplemental Notice for Mexico Users

If you are located in Mexico, this policy serves as Luvu’s privacy notice for the purposes described here, including operating the services, administering rewards and cash-outs, improving and training Luvu systems, and, with your onboarding consent where required by applicable law, transferring, providing, or licensing voice clips and related data described in this policy to AI Partners, including recipients in the United States and other countries. You may exercise your rights of access, rectification, cancellation, and opposition; revoke consent; or request limitation of use or disclosure of your personal data by contacting support@luvufit.com, subject to applicable law. Consent withdrawal stops future collection and future AI Partner licensing where we can reasonably do so, but it does not affect processing that occurred before withdrawal or data already licensed to an AI Partner. You may also contact Mexico’s National Institute for Transparency, Access to Information and Personal Data Protection (INAI) where applicable.

(c) Supplemental Notice for EU/UK and Swiss Users

If you are located in the European Economic Area, the United Kingdom, or Switzerland, the following additional information applies to our processing of your personal data under the General Data Protection Regulation (GDPR), the UK GDPR, and the Swiss Federal Act on Data Protection (FADP), as applicable.

Legal Basis for Processing. We process your personal data on the following legal bases: Contract performance, to provide and maintain the services you requested; Legitimate interests, to operate, improve, and secure our services, provided our interests are not overridden by your data protection rights (our legitimate interests include fraud prevention, network security, product improvement, and direct marketing to existing customers); Consent, where you have given specific consent, such as for marketing communications, model training, synthetic voice use, voice cloning, digital replicas, biometric processing, or AI Partner licensing (you may withdraw consent at any time by contacting us at support@luvufit.com or changing the relevant account setting, but withdrawal does not affect processing that occurred before withdrawal); and Legal obligation, where processing is required to comply with applicable law.

International Transfers. Your personal data is transferred to and processed in the United States, which the European Commission has not determined provides an adequate level of data protection. We protect these transfers using the European Commission’s Standard Contractual Clauses, with the Swiss addendum where applicable. You can request a copy by contacting us at support@luvufit.com.

Your Additional Rights Under GDPR. In addition to the rights described above, EU, UK, and Swiss residents have the right to: object to processing of your personal data based on legitimate interests; restrict processing of your personal data in certain circumstances; withdraw consent at any time, where our processing is based on your consent, without affecting the lawfulness of processing carried out before withdrawal; not be subject to a decision based solely on automated processing that produces legal or similarly significant effects concerning you, except as permitted by law; and lodge a complaint with your local data protection supervisory authority.

20. Other Sites and Services

Our services may link to, or integrate with, websites and online services operated by third parties that we do not control. A link or integration is not an endorsement, and we are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party sites and services you use.

21. Changes to This Policy

We may update this policy from time to time. The “Last Updated” date at the top reflects the most recent change. If we make a material change, we will take reasonable steps to notify you.

22. Contact

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