Privacy Policy

Effective Date: March 10, 2026

LUX Training ("LUX", "we", "us", or "our") is a sexual performance training application designed to help men manage premature ejaculation through guided exercises and coaching. This Privacy Policy explains how we collect, use, store, and protect your information when you use our mobile application (the "App").

LUX is operated by Alberto, an individual developer based in Italy. As such, we process personal data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, or "GDPR").

1. Data Controller

The data controller responsible for your personal data is:

2. What Data We Collect

We collect the minimum data necessary to provide the service. The data falls into three categories based on where and how it is stored.

2.1 Server-Side Data (Firebase / Firestore)

Data	Purpose	Legal Basis (GDPR)
Anonymous Firebase UID	Identify your account and link your data	Legitimate interest (Art. 6(1)(f))
Email address (only if you create an email account)	Account authentication and recovery	Contract performance (Art. 6(1)(b))
Display name	Personalise the app experience	Contract performance (Art. 6(1)(b))
Onboarding answers: age range, training goals, duration/history questions, emotional responses (frustration, alcohol use, masculinity, avoidance patterns)	Generate a personalised training programme	Explicit consent (Art. 6(1)(a) / Art. 9(2)(a) for health-related data)
Feedback submissions: message, category, optional email, locale, platform	Respond to support requests and improve the App	Legitimate interest (Art. 6(1)(f))

2.2 Device-Local Data (SharedPreferences)

The following data is stored exclusively on your device and is never transmitted to our servers:

• Exercise session history and completion data
• Journal entries
• Mood and performance tracking
• Streak and progress data
• Training blocks and daily schedules

Because this data never leaves your device, it is not subject to server-side data processing. Uninstalling the App permanently deletes this data.

2.3 AI Coach Conversations

When you use the AI coaching feature, your conversation context (including relevant onboarding data and training progress) is sent to the Anthropic Claude API for processing. These conversations are used solely to generate a response and are not stored on our servers after the response is delivered. For Anthropic's data handling practices, see Anthropic's Privacy Policy.

3. Special Category Data

Some onboarding answers (e.g., relating to sexual health, emotional well-being, and alcohol use) may constitute special category data under Article 9 of the GDPR. We process this data only with your explicit consent, which you provide during onboarding. You may withdraw consent at any time by contacting us or deleting your account.

4. Third-Party Services

We use the following third-party services to operate the App:

4.1 Firebase (Google)

• Firebase Authentication — manages account creation (anonymous or email-based)
• Cloud Firestore — stores onboarding answers, display name, and feedback

Firebase processes data in accordance with Google's data processing terms. Data may be processed in the EU/EEA or the United States under Standard Contractual Clauses. See Firebase Privacy and Security.

4.2 Anthropic (Claude API)

Used to power the AI coaching feature. Conversation data is sent to Anthropic's API for real-time processing. See Anthropic's Privacy Policy.

4.3 RevenueCat

Used to manage subscriptions and in-app purchases. RevenueCat receives a pseudonymous app user ID and purchase transaction data from Apple App Store or Google Play. See RevenueCat's Privacy Policy.

4.4 What We Do Not Use

• We do not use third-party analytics or tracking tools.
• We do not display advertisements.
• We do not sell, rent, or share your personal data with third parties for their own marketing purposes.

5. Data Retention

• Server-side data (Firestore): retained for as long as your account exists. When you delete your account, all associated server-side data is permanently deleted within 30 days.
• Device-local data (SharedPreferences): retained on your device until you uninstall the App or clear its data.
• AI coach conversations: not retained on our servers after the response is generated.
• Feedback submissions: retained for up to 24 months to support product improvement, then deleted.

6. Data Security

We implement appropriate technical and organisational measures to protect your data, including:

• All data in transit is encrypted via TLS/HTTPS
• Firestore Security Rules restrict access to authenticated users' own data
• Sensitive device-local data is stored using platform-native secure storage
• No plaintext passwords are ever stored (authentication is handled by Firebase)

7. International Data Transfers

Your data may be transferred to and processed in the United States by our third-party service providers (Firebase/Google, Anthropic, RevenueCat). These transfers are safeguarded by Standard Contractual Clauses (SCCs) approved by the European Commission, or equivalent mechanisms as required by applicable law.

8. Your Rights Under the GDPR

As a data subject in the EU/EEA, you have the following rights:

• Right of access (Art. 15) — request a copy of all personal data we hold about you
• Right to rectification (Art. 16) — correct inaccurate personal data
• Right to erasure (Art. 17) — request deletion of your personal data ("right to be forgotten")
• Right to restriction of processing (Art. 18) — request that we limit how we process your data
• Right to data portability (Art. 20) — receive your data in a structured, machine-readable format
• Right to object (Art. 21) — object to data processing based on legitimate interest
• Right to withdraw consent (Art. 7(3)) — withdraw consent at any time for processing based on consent

To exercise any of these rights, contact us at privacy@luxtraining.app. We will respond within 30 days as required by the GDPR.

You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or any other competent supervisory authority.

9. Account Deletion

You can delete your account at any time from within the App (Settings > Delete Account). This will:

• Permanently delete all server-side data associated with your account (Firestore documents, Firebase Auth record)
• Revoke any active subscriptions will need to be cancelled separately through the App Store or Google Play

Device-local data is removed when you uninstall the App.

10. Children's Privacy

LUX is intended for users aged 18 and older. We do not knowingly collect personal data from anyone under the age of 18. If we learn that we have collected data from a minor, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the App or by other appropriate means. The "Effective Date" at the top of this page indicates when the policy was last revised.

12. Contact Us

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

This Privacy Policy is effective as of March 10, 2026.