Data Privacy Policy

The Lugelo, website, mobile app and accompanying services give you the power to share content that you provide. This privacy policy outlines what information is collected and stored at Lugelo. As you review our policy, keep in mind that it applies to all Lugelo products and services that do not have a separate privacy policy.

Lugelo, Inc. (“we,” “us,” or “our”) operates the Lugelo application and related websites (each, an “App” or a “Website”, respectively) and several related services (all such services, “Services”). Through our App and Services, we offer you a journaling program to record your memories, and, if you wish, share them with others as well using our custom features in the App and Website.

You will be notified of any changes to this policy and give you the opportunity to accept the revised policy before continuing to use our services.

1. Information we collect

Depending on which Services you use, we collect different kinds of information from or about you.

Things others do and information they provide.

We also collect content and information that other people provide when they use our Services, including information about you, such as when they share a journal with you, or comment on your journal.

Device information.

We collect information from or about the computers, phones, or other devices where you install or access our Services, depending on the permissions you’ve granted. We may associate the information we collect from your different devices, which helps us provide consistent Services across your devices. Here are some examples of the device information we collect: Attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers. Device locations, including specific geographic locations, such as through GPS, Bluetooth, or Wi-Fi signals.

Account Information.

To use the core features of our Services, you must register through the App with our Services and open an “Account” with us by providing your name, email address, and a password. We retain information on your behalf, such as entries, pages and messages that you store using your Account.

Journal Information.

The most important thing we store is your journals. By default, your journals are private. Individual journals may be shared publicly or privately with family and friends only.

Support Information.

We collect other personal information that you submit to us voluntarily as you use our App, Website and Services. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, to send you a reply. You can choose not to provide us with certain information, but this may limit the features of the Services you are able to use.

Location Information.

In some cases, we may collect and store information about where you are located, such as by converting your IP address into a rough geolocation or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device. Of course, your location may also be apparent from your entries.

Third-Party Payment Processing.

We may sell subscriptions or merchandise through our Services. When you make purchases through the Services, we process your payments through a third-party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”), Social Networking Sites (“SNS”) such as Facebook, and other third-party payment processers, including Stripe. The third-party application may collect certain financial information from you to process the payment, including your name, email address, address and other billing information.

Google Account Information.

When you connect your Google account, we may access certain Google user data such as your name, user ID, email, etc. to allow you to access features more seamlessly. For example, you may be able to log in to Lugelo quicker using your Google account or we may be able to backup your data onto your Google Drive for you.

Log Files.

As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.


Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.

We use Google Analytics to help analyze how users use the Site. Google Analytics uses Cookies to collect information such as how often users visit the Site, what pages they visit, and what other sites they used prior to coming to the Site. We use the information we get from Google Analytics only to improve our Site and Services. Google Analytics collects only the IP address assigned to you on the date you visit the Site, rather than your name or other personal information. We do not combine the information generated using Google Analytics with your personal information. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Site, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Mobile Services.

We may also collect information from your mobile device if you have downloaded our App to your mobile device or used our Website on your mobile device. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the App and Website, and information about the type of device you use. In addition, in the event our App crashes on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our App and Website. This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.

Information from websites and apps that use our Services.

We collect information when you visit or use third-party websites and apps that use our Services. This includes information about the websites and apps you visit, your use of our Services on those websites and apps, as well as information the developer or publisher of the app or website provides to you or us. We use google, Facebook and Twitter APIs to import data to Lugelo. We use Oauth 2.0 to collect this information after your authorization and we do not store any kind of username or password of your social accounts. Using Oauth 2.0 it allows you to import data from Google, Facebook and Twitter on your behalf.

2. How do we use this information?

We are passionate about creating engaging and customized experiences for people. We use all of the information we have to help us provide and support our Services. Here’s how:

Provide, Improve and Develop Services.

We are able to deliver our Services, personalize content, and make suggestions for you by using this information to understand how you use and interact with our Services. We conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve products and services, develop new products or features, and conduct audits and troubleshooting activities.

Communicate with you.

We use your information to communicate with you about our Services and let you know about our policies and terms. We also use your information to respond to you when you contact us.

We will communicate with you primarily in the form of push alerts and emails. You can manage the frequency and/or opt out of receiving these communications by changing your settings on the Website and App and/or clicking on the “Unsubscribe” link at the bottom of each marketing email. Note, that even if you unsubscribe, we may still send you App and Website related communications (e.g., emails, SMS or Alerts related to your account).

Promote safety and security.

We use the information we have to help verify accounts and activity, and to promote safety and security on and off of our Services, such as by investigating suspicious activity or violations of our terms or policies. We work hard to protect your account using teams of engineers, automated systems, and advanced technology such as encryption and machine learning. We use cookies and similar technologies to provide and support our Services and each of the uses outlined and described in this section of our policy. Read our Cookie Policy to learn more

3. How is this information shared?

People use our Services to connect and share with others. We make this possible by allowing you to share your information in the following ways:

People you share and communicate with.

Lugelo enables users to handpick selected journals to share. Our display of shared journals is subject to the privacy settings you establish for them. You can share your selected journal/s privately with a one or more people or make your journal public for every Lugelo user to read. When you share journals and their content (text, images, photographs, messages, comments or any other kind of content that is not your e-mail address) as part of our Services, other users may be able to see it, including visitors to the Site. Please remember this and be thoughtful about what you publish.

When you share and communicate using our Services, you choose the audience who can see what you share. For example, when you share a journal on Lugelo, you select the audience for the journal, such as a customized group of individuals or everyone (Public). Public Information is any information you share with a public audience. Public information is available to anyone on or off our Services and may or can be seen or accessed through online search engines, and offline media, such as on TV. In some cases, people you share and communicate with, privately or publicly, may download this content off our Services and share that content with others using other services.

People that see content others share about you.

Other people may use our Services to share content about you with the audience they choose. For example, people may share a photo of you or share information about you that you shared with them. If you have concerns with someone’s content, contact our Abuse Support Team and we will investigate.

New Owner

If the ownership or control of all or part of our Services or their assets changes, we may transfer your information to the new owner.

In connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.

In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will

We also disclose certain personal information.

  • - To third party vendors who help us provide the Services or the Website;
  • - Assume the rights and obligations regarding your personal information as described in this Privacy Policy.
  • - If we believe in good faith that such disclosure is necessary to (a) resolve disputes, investigate problems, or enforce our Terms of Service; (b) comply with relevant laws or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity, in which case we can (and you authorize us to) disclose personal information without subpoenas or warrants served on us; or (c) protect and defend our rights or property or the rights and property of you or third parties.

If you share your journal/s certain of your content, it will be made publicly available. This means that anyone may see it on the App or Website along with certain of your related profile information. Please be thoughtful about the journals you share. In addition, our App and Services may enable you to post content to SNSs (e.g., Facebook or Twitter). If you choose to do this, we will provide information to such SNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third-party provider of such SNSs. We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs.

Anonymous Information.

We reserve the right to disclose anonymous information or other information that cannot reasonably be used to identify you publicly without restriction.

Information Disclosed to Third Parties.

This Privacy Policy addresses only our use and disclosure of information we collect from and/or about you on the Website or from the App and Services. If you disclose information to others, the use and disclosure restrictions contained in this Privacy Policy will not apply to any third party. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.

The App and Website may contain content or links to other websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our App or Website and go to another site. During this process, another entity may collect personal information or Other Information from you. The App and Website may also contain links to other websites controlled by us but which may operate under different privacy policies. Please review the privacy policy of any new site you visit.

Outside of the United States.

A Note to Users Outside of the United States. If you are a non U.S. user of the App or Services, by visiting the Site and/or providing us with information, you acknowledge that your personal information may be processed for the purposes identified in the Privacy Policy. In addition, your personal information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. By providing your information, you consent to such transfer

4. How can I manage or delete information about me?

We store data for as long as it is necessary to provide products and Services to you. Information associated with your account will be kept until your account is deleted unless we no longer need the data to provide products and Services. You can delete your account any time - See instructions below. When you delete your account, we delete all journals and moments you have posted, such as your photos, videos, audios, eBooks and comments. Keep in mind that information that others have shared about you is not part of your account and will not be deleted when you delete your account.

Deleting Account :To delete your account, login via a web browser and go to My Account at the top right corner under the profile image. you will see the option to Delete your account. You must initiate the delete action as our privacy and security settings prevent our engineers from deleting content on your behalf. Once you request for deletion of your account, our system will start the process to delete your information in a reasonable time, however we may retain certain information as permitted or required by law.

5. How do we respond to legal requests or prevent harm?

We may access, preserve and share your information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; or to prevent death or imminent bodily harm. Information we receive about you, including financial transaction data related to purchases made with Lugelo, may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm. We also may retain information from accounts disabled for violations of our terms for at least a year to prevent repeat abuse or other violations of our terms.

Changes to this Privacy Policy.

This Privacy Policy is subject to revision from time to time on a going-forward basis. We will post any revised version of the Privacy Policy on this page.

Questions about the Privacy Policy.

TIf you have any questions or concerns or complaints about our Privacy Policy or our information collection or processing practices, or if you want to report any security violations to us, please contact us at