Privacy Policy

Last Updated: July 3, 2026

SyncUp Studio ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains our practices regarding the collection, use, disclosure, and safeguarding of your information when you use the Luma mobile application (the "App").

By downloading, accessing, or using the App, you agree to the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the application.

1. Information We Collect

As an education and English learning application, Luma is designed with data minimization in mind.

• Personal Data: We do not require you to register for an account, nor do we collect personal identifiers such as your name, physical address, or phone number.

• Microphone & Audio Data: The App utilizes your device's microphone solely for English pronunciation scoring and speaking exercises. This audio data is processed in real-time or sent temporarily to our secure servers exclusively for the purpose of speech recognition and grading. We do not use your voice data to identify you, nor do we sell or share this data with unauthorized third parties.

• Automatically Collected Data: When you use the App, we may automatically collect certain device and usage information through integrated third-party analytics tools. This may include your device type, operating system, advertising identifiers (e.g., Google Advertising ID), IP address, and app usage statistics (e.g., session duration, crash reports).

2. Permissions Explained

To provide you with core educational functionalities, Luma requires certain system permissions on your device. We only request permissions strictly necessary for the App's operation. We do not collect data through these permissions when the App is not in use.

• RECORD_AUDIO (Microphone)

• This permission is required for our core speaking exercises. We only request this permission dynamically when you actively tap the record button to practice your pronunciation. The audio is strictly used for real-time grading and speech recognition purposes.

• INTERNET & ACCESS_NETWORK_STATE

• These permissions are necessary for the App to connect to the internet, fetch updated learning materials and audio files, communicate with backend interfaces, and allow our integrated analytics SDKs (like Firebase) to transmit anonymous crash logs and performance data securely.

• POST_NOTIFICATIONS

• For devices running Android 13 or higher, we request this permission to send you daily learning reminders, study streaks, and important system notifications. You can manage or revoke this permission at any time in your device settings.

• WAKE_LOCK

• Used by Google and Firebase components to briefly keep your device's processor from sleeping while finishing crucial background tasks, such as processing analytics or crash reports, ensuring the App runs smoothly.

• AD_ID, ACCESS_ADSERVICES_AD_ID & ACCESS_ADSERVICES_ATTRIBUTION

• These are standard permissions introduced by Google Play Services and the Android Privacy Sandbox. They are used for app installation attribution and non-personalized analytics purposes. We use this data to understand how users discover our App without tracking your identity across other applications.

• BIND_GET_INSTALL_REFERRER_SERVICE

• Required by Google Play to securely retrieve data regarding how you installed the App, which helps us attribute downloads and improve our product offerings.

• DYNAMIC_RECEIVER_NOT_EXPORTED_PERMISSION

• This is an internal security-level permission automatically generated by AndroidX/Core. It restricts external applications from interacting with Luma's internal dynamic broadcast receivers, keeping your App sessions secure.

3. Third-Party Services

We may employ third-party companies and SDKs to facilitate our App, perform App-related services, or assist us in analyzing how our App is used. These third parties have access to your automatically collected data only to perform these tasks on our behalf.

• Google Play Services: Used for core Android functionalities, install attribution, and app distribution. View Google Privacy Policy

• Firebase Analytics & Crashlytics: We use Firebase (provided by Google) to track app performance, analyze user engagement, and log crash reports. This helps us improve the stability of Luma. View Firebase Privacy Policy

4. Children's Privacy

Luma is an English learning tool and is not directed at children under the age of 13 (or the equivalent minimum age in your jurisdiction). We adhere strictly to the Children's Online Privacy Protection Act (COPPA) and Google Play's Families Policy.

While the visual design, branding, or icon of the App may inadvertently appeal to younger audiences, we do not knowingly collect, solicit, or maintain personal information from anyone under the age of 13. If a parent or guardian becomes aware that their child has provided us with information without their consent, they should contact our Data Protection Officer immediately, and we will take steps to delete such data from our servers.

5. Global Privacy Rights

Depending on your region, you may have specific rights regarding your personal information. SyncUp Studio respects global privacy frameworks, including:

• European Economic Area (EEA) & UK: Under the General Data Protection Regulation (GDPR), you have the right to access, rectify, or erase your data, and the right to object to data processing.

• California, USA: Under the California Consumer Privacy Act (CCPA) as amended by the CPRA, California residents have the right to know what personal data is being collected, the right to delete data, and the right to opt-out of the sale of personal information. (Note: We do not sell your personal data).

• Virginia, USA: We comply with the Virginia Consumer Data Protection Act (VCDPA).

• Brazil: Under the Lei Geral de Proteção de Dados Pessoais (LGPD), Brazilian users possess rights regarding the confirmation, access, correction, and anonymization of their data.

6. Data Transfer

SyncUp Studio operates primarily in Mainland China. However, the data collected via third-party SDKs (such as Firebase) may be transferred to, stored, and processed in servers located outside of your country of residence (e.g., the United States). By using Luma, you consent to this transfer, storage, and processing.

7. Changes to This Privacy Policy

We may update our Privacy Policy from time to time to reflect changes in our practices or global compliance requirements. We will notify you of any changes by updating the "Last Updated" date at the top of this policy. You are advised to review this Privacy Policy periodically for any changes.

8. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your data rights, please contact our Data Protection Officer (DPO):

• DPO Name: Jiang Xiaoyan

• Email: syncuptechnology@gmail.com