Privacy Policy

Last updated: March 27, 2026

Lure ("we", "our", or "us") is committed to protecting your privacy and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR) where applicable. This Privacy Policy explains how we handle information when you use the Lure travel planning application ("App").

1. Who We Are (Data Controller)

The data controller for the purposes of GDPR is the individual operator of Lure, based in Spain. For any data-related enquiries, please contact us at: vitalysuvorov23@gmail.com

2. What Data We Collect and Why

a) Server Logs (via Netlify)
The App is hosted on Netlify. As part of standard web hosting operations, Netlify automatically collects technical logs including IP addresses, browser type, device type, and pages accessed. This data is processed by Netlify on the basis of legitimate interests (Article 6(1)(f) GDPR) — specifically, to ensure the security, stability, and performance of the service. We do not have direct access to or control over these logs. Netlify retains server logs for a limited period in accordance with their own data retention policy. Please refer to Netlify's Privacy Policy and their Data Processing Agreement.

b) Purchase Data (Google Play Billing & RevenueCat)
If you make an in-app purchase, the transaction is processed by Google Play. We use RevenueCat to manage and verify purchase entitlements. We receive only a transaction ID and a purchase token, which are used solely to verify and unlock your purchased content. We do not receive your payment card details, name, or billing address. This data is processed on the basis of contract performance (Article 6(1)(b) GDPR). Purchase records are retained for as long as necessary to support your access to purchased content and to comply with applicable tax and accounting obligations (typically 7 years in Spain under Ley General Tributaria).

c) Feedback Emails
If you contact us via the feedback button, we receive your email address and the content of your message. This is processed on the basis of legitimate interests (Article 6(1)(f) GDPR) in order to respond to your enquiry. We do not add you to any mailing list. Feedback emails are retained for up to 12 months unless you request deletion.

3. What We Do NOT Collect

4. Local Storage

The App stores certain data locally on your device using your browser's local storage — specifically, your unlocked city purchases and onboarding status. This data never leaves your device and is deleted when you uninstall the App. It does not constitute personal data collection by us.

5. Third-Party Services and Data Processors

6. International Data Transfers

Some of our third-party processors (including Google and RevenueCat) operate in the United States. These transfers are covered by appropriate safeguards — specifically, the EU–US Data Privacy Framework and/or Standard Contractual Clauses (SCCs) approved by the European Commission.

7. Data Retention

8. Your Rights Under GDPR

If you are located in the European Economic Area (EEA), you have the following rights regarding your personal data:

To exercise any of these rights, contact us at vitalysuvorov23@gmail.com. We will respond within 30 days.

Note: since we collect minimal personal data, in many cases there will be little or nothing to action. We will always confirm this clearly.

9. Right to Lodge a Complaint

If you believe we have not handled your data correctly, you have the right to lodge a complaint with a supervisory authority. In Spain, the relevant authority is:

Agencia Española de Protección de Datos (AEPD)
www.aepd.es

You may also contact the supervisory authority in your country of residence within the EEA.

10. California Privacy Rights (CCPA)

If you are a California resident, you have the right to know what personal information we collect, the right to delete it, and the right to opt out of its sale. We do not sell personal information. To exercise your rights, contact us at vitalysuvorov23@gmail.com.

11. Children's Privacy

The App is not directed at children under the age of 13 (or 16 in jurisdictions where a higher age applies). We do not knowingly collect personal information from children. If you believe a child has used the App and provided personal information, please contact us and we will take appropriate steps to delete such information.

12. Content Disclaimer

Lure provides travel recommendations and itineraries for informational purposes only. While we strive to keep all information accurate and up to date, we make no guarantees regarding the accuracy, completeness, or current status of any place, venue, opening hours, pricing, or other information presented in the App.

Places may close, relocate, or change. We strongly recommend verifying details directly with venues before visiting. Lure is not responsible for any loss, inconvenience, or disappointment arising from reliance on information provided in the App. Use of the App and its recommendations is entirely at your own risk.

13. In-App Purchases

Lure offers one-time purchases that unlock access to city guide content ("Lifetime Purchases"). These purchases grant you access to the relevant content for as long as the App is actively maintained and available.

We make no guarantee that the App will remain available indefinitely. In the event that we decide to discontinue the App or remove specific content, we will provide reasonable advance notice (no less than 30 days) within the App where practicable. We are not obligated to provide refunds in such circumstances, though we will endeavour to act fairly and in accordance with applicable consumer protection laws.

Purchases are processed and managed by Google Play. Refund requests are subject to Google Play's refund policy. You may also contact us directly at vitalysuvorov23@gmail.com to request a refund within 14 days of purchase, and we will consider each request on its merits.

Your purchases are automatically restored when you relaunch the App with an internet connection.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify users of significant changes by updating the "Last updated" date at the top of this page. For material changes, we will provide notice within the App where reasonably practicable. Continued use of the App after changes constitutes acceptance of the updated policy.

15. Contact Us

For any questions, requests, or concerns regarding this Privacy Policy or your personal data:

vitalysuvorov23@gmail.com