Welcome toLUCILLA
Last Updated: April 17, 2026
Welcome to Lucilla ("we," "our," or "us"). We are committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and services.
We collect information that you provide directly to us, including:
With your explicit consent, we collect:
When you connect a wearable or fitness device to Lucilla, we collect:
How We Use Wearable Data:
Disconnecting Your Wearable: You can disconnect your wearable device at any time through the app settings. Please note that disconnecting a wearable will prevent your participation in matches that require that device as a verified step source.
Lucilla integrates with the following third-party wearable and health platforms to read fitness data on your behalf, only after you have granted explicit permission via the platform's official authorization flow (OAuth, HealthKit, Health Connect, or equivalent):
Data we read from these wearable APIs:
Purpose of collection. Lucilla reads the data above for the sole purpose of (1) validating fitness challenge and step-match results, (2) confirming verified in-person visits for reward claims, (3) calculating reward and USDC prize eligibility, and (4) displaying your activity back to you inside the Lucilla app. We do not sell wearable data to third parties, do not use it for advertising, and do not share it with enterprise partners in identifiable form.
Garmin Health API specific notice. Health and activity data obtained through the Garmin Health API (steps, activities, heart rate, calories, intensity minutes, daily summaries) is used exclusively to verify step matches, validate fitness challenge results, and award USDC and reward prizes inside the Lucilla app. Garmin data is stored encrypted at rest, accessed only by authorized backend services on a need-to-process basis, and is never sold, rented, or licensed to third parties. You can disconnect your Garmin account at any time from Settings > Connected Devices > Garmin in the Lucilla app, which immediately revokes our OAuth token with Garmin and stops all further data ingestion. You can additionally request deletion of all Garmin-derived data we have stored by emailing s.borjas@lucilla.ca — we will purge it within 30 days, subject only to the FINTRAC retention exception described in Section 6 (which applies only to records linked to a settled USDC transaction).
Apple HealthKit Notice: Health data obtained from Apple HealthKit is used solely to provide and improve App features. We do not use HealthKit data for advertising, and we do not share HealthKit data with third parties except as required to operate the App or as required by law.
Fitbit Web API specific notice. Health and activity data obtained through the Fitbit Web API (steps, intraday step data, workouts, heart rate, calories, sleep, daily summaries) is used exclusively to verify step matches, validate fitness challenge results, and award USDC and reward prizes inside the Lucilla app. Fitbit data is stored encrypted at rest, accessed only by authorized backend services on a need-to-process basis, and is never sold, rented, or licensed to third parties. You can disconnect your Fitbit account at any time from Settings > Connected Devices > Fitbit in the Lucilla app, which immediately revokes our OAuth token with Fitbit (and your authorization is also manageable from https://www.fitbit.com/settings/applications) and stops all further data ingestion. You can additionally request deletion of all Fitbit-derived data we have stored by emailing s.borjas@lucilla.ca — we will purge it within 30 days, subject only to the FINTRAC retention exception described in Section 6 (which applies only to records linked to a settled USDC transaction).
Google Fit / Health Connect specific notice. Health and activity data obtained through the Google Fit REST API and the Android Health Connect platform (steps, exercise sessions, heart rate, calories, distance, sleep) is used exclusively to verify step matches, validate fitness challenge results, and award USDC and reward prizes inside the Lucilla app. Google-derived data is stored encrypted at rest, accessed only by authorized backend services on a need-to-process basis, and is never sold, rented, or licensed to third parties. Lucilla's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. You can disconnect Google Fit at any time from Settings > Connected Devices > Google Fit (or revoke access at https://myaccount.google.com/permissions), and you can revoke Health Connect read permissions at any time from your Android device's Health Connect settings. You can additionally request deletion of all Google-derived data we have stored by emailing s.borjas@lucilla.ca — we will purge it within 30 days, subject only to the FINTRAC retention exception described in Section 6 (which applies only to records linked to a settled USDC transaction).
Samsung Health specific notice. Health and activity data obtained from Samsung Health (via Health Connect or the Samsung Health SDK on Galaxy Watch and Galaxy phone surfaces — steps, exercise sessions, heart rate, sleep, calories) is used exclusively to verify step matches, validate fitness challenge results, and award USDC and reward prizes inside the Lucilla app. Samsung Health data is stored encrypted at rest, accessed only by authorized backend services on a need-to-process basis, and is never sold, rented, or licensed to third parties. You can disconnect Samsung Health at any time from Settings > Connected Devices > Samsung Health in the Lucilla app, and you can additionally revoke Lucilla's read permission inside the Samsung Health app or via Android Health Connect at the OS level. You can request deletion of all Samsung-derived data we have stored by emailing s.borjas@lucilla.ca — we will purge it within 30 days, subject only to the FINTRAC retention exception described in Section 6 (which applies only to records linked to a settled USDC transaction).
You may optionally share certain health data with the Lucilla community:
All health sharing is opt-in and user-initiated. Nothing is shared automatically. You control visibility (public, followers, groups, or paid subscribers only) and may delete shared posts at any time.
Web community feed (lucilla.ca) is force-anonymized. When you opt a journal / macros / exercise entry into the public community feed that powers lucilla.ca, the server strips your username, user ID, and profile picture at read time so web visitors see the content without being able to identify you. This is a one-way transformation handled server-side. The only de-anonymization path is an admin-only audit endpoint used exclusively for legal-hold or law-enforcement requests — ordinary staff and other users cannot resolve an anonymized entry back to an account.
Enhanced Profile paid subscriptions are the ONLY identified share path. Inside the app, a user may enable a creator subscription on their Enhanced Social Profile (Profile > Creator Pricing). Paid subscribers then see that creator's live macros / exercise / journal feed with full identity attached. Non-subscribers (including strangers, followers, friends, or people the creator follows — depending on the audience tier the creator chose) see a paywall stub plus at most aggregate daily-total teasers. This is a direct creator-to-subscriber relationship facilitated by Lucilla; the platform fee follows the creator's subscription tier. Server-side rules at Users/{uid}/journal_entries block every non-owner read path from reaching raw data without going through the getCreatorTrackingView / getNetworkTrackingFeed Cloud Functions, which enforce the subscription / audience tier.
You can revoke microphone access at any time in your device Settings.
We never receive or store your biometric data. When you set up your Lucilla Smart Wallet via WebAuthn passkey, authentication happens entirely on your device through Apple or Google's secure enclave. We only receive a cryptographic token confirming successful authentication — your fingerprint or face data never leaves your device.
For users utilizing our USDC wallet features:
We collect information about the device you use to access Lucilla, including:
This information helps us provide a consistent experience, troubleshoot issues, and ensure platform security.
When you use location-based features (such as geo-rewards), we collect:
We collect this location intelligence data to improve reward targeting and provide more relevant offers near you, to prevent fraud and ensure fair reward distribution for all users, and to enhance platform safety through anti-spoofing measures.
When you interact with rewards and business campaigns, we collect:
This data helps us optimize campaign performance and provide you with more relevant reward opportunities.
To maintain a fair and secure platform for all users, we collect and process:
For enterprise (business) customers, we additionally collect:
We use your information to:
Lucilla Technologies Inc. owns and retains all data generated through your use of the platform. We use this data to operate, improve, and personalize our services.
Your health and fitness data is protected under strict security measures:
Lucilla integrates cryptocurrency functionality for rewards and payments. Important disclosures:
IMPORTANT: Cryptocurrency involves significant risks:
Lucilla does not provide investment, financial, tax, or legal advice. Any cryptocurrency features are provided "as-is" for rewards and payment purposes only. Consult qualified professionals for financial decisions.
While Lucilla's core features (health tracking, social, Step Matches) are available worldwide, certain cryptocurrency services have geographic restrictions:
Lucilla retains personal data only as long as necessary to provide the service, comply with legal obligations, resolve disputes, and enforce agreements. When you delete your account, most personal data is removed immediately. Some records must be retained for a fixed period due to Canadian money-services-business law (FINTRAC, under the Proceeds of Crime Act), the Canada Revenue Agency business-records rule, and similar laws where you reside. The table below lists exactly what we keep, for how long, and why.
| Data category | Retained after account deletion | Legal basis |
|---|---|---|
| Profile (name, photo, username, bio, email, phone, DOB) | Deleted immediately | — |
| Social posts, journal entries, chat messages | Deleted immediately | — |
| Step / activity / sleep data | Deleted immediately | — |
| Profile photos and uploaded media | Deleted immediately | — |
| Push tokens, device identifiers | Deleted immediately | — |
| Firebase Auth login | Deleted immediately (day 1) | — |
| Wallet address(es) | 5 years, then purged | FINTRAC PCMLTFA (Canadian MSB) |
| USDC transactions (rewards paid, wagers, escrow payouts) | 5 years, then purged | FINTRAC PCMLTFA |
| Reward claims with USDC value | 5 years, then purged | FINTRAC PCMLTFA |
| Match wagering records and escrow resolutions | 5 years, then purged | FINTRAC PCMLTFA |
| Identifying info (name, email, phone, DOB) linked to the records above | 5 years, then purged | FINTRAC requires identity be linked to transaction records |
| Tax-relevant business records | 6 years | Canada Revenue Agency |
| On-chain transaction hashes and wallet balances | Permanent | Blockchain is immutable by design — published to the Base network |
| Aggregated analytics (no personal identifiers) | Indefinite | No PII — used for platform improvement |
The retention vault. On the day you delete your account, the records marked "5 years, then purged" are moved into a locked retention vault that only compliance auditors can access. You can no longer see or control them, but they exist for audit response until the retention period ends. Once the 5-year retention period expires, a scheduled process permanently deletes the vault record for that user.
Why we link identity to transaction records. FINTRAC's record-keeping rules require that a money-services business be able to identify the person behind any transaction it processed. Keeping only the wallet address and amount isn't enough — regulators need to know which real person held that wallet. This is why your name, email, phone, and date of birth stay in the vault alongside your transaction history.
Your rights. GDPR (EU), CCPA (California), and Canadian privacy law all grant a right to erasure. That right is subject to a legal-obligation exception (GDPR Article 17(3)(b); CCPA § 1798.105(d)) which is what the retention above relies on. You may always request a copy of your retained records by emailing privacy@lucilla.ca. If you believe your data has been retained longer than necessary, or you want to dispute the retention, contact the same address — we respond within 30 days.
Partial data deletion. You may request deletion of specific data categories without deleting your whole account (social posts, journal, step history, device identifiers, subscription tracking) via /delete-data. Reward claims, match history, and transactions cannot be partially deleted — those are governed by FINTRAC retention and are only removed via full account deletion into the retention vault.
You have the right to:
If you are a California resident, you have additional rights under the California Consumer Privacy Act and the California Privacy Rights Act:
To exercise these rights, contact us at s.borjas@lucilla.ca. We will respond within 45 days.
If you are located in the European Economic Area, United Kingdom, or Switzerland, you have the following rights under the General Data Protection Regulation:
Legal Bases for Processing:
To exercise these rights, contact our Data Protection contact at s.borjas@lucilla.ca.
Canadian users have rights under the Personal Information Protection and Electronic Documents Act, including the right to access, correct, and withdraw consent for the collection and use of personal information.
Residents of Virginia, Colorado, Connecticut, Nevada, and other states with consumer privacy laws have rights similar to those described above under their respective state laws. Contact us to exercise these rights.
We retain your information for as long as your account is active or as needed to provide services:
Even if you delete your account, transaction data and compliance records will be retained for the full 7-year period to comply with federal law.
Lucilla is not directed to children under 13. We do not knowingly collect personal information from anyone under the minimum age that applies in their jurisdiction: 13 in the United States (COPPA), 14 in most Latin American countries, 15 in France, and 16 in Germany and most EU member states (GDPR-K). If we learn a user is under the applicable minimum age, we will delete the account and associated data.
Paid step-match competitions require users to be at least 18 years old (19+ in British Columbia, Alberta, Manitoba, Quebec, Nova Scotia, and PEI). Age is verified in two stages:
If the ID shows the user is under 18:
We implement industry-standard security measures including:
Your data may be transferred to and processed in countries outside your residence, primarily the United States and Canada. We ensure appropriate safeguards are in place for international transfers, including standard contractual clauses where required.
App distribution footprint: The Lucilla app is currently distributed to approximately 145 countries on the Apple App Store and approximately 157 countries on the Google Play Store. Countries currently excluded from one or both stores due to US sanctions, regulatory restrictions, or pending local registrations include (non-exhaustive): Afghanistan, Algeria, Belarus, Bhutan, Brazil, Brunei, China mainland, Cuba, Egypt, India, Iran, Iraq, North Korea, Libya, Madagascar, Malawi, Mauritania, Morocco, Nepal, Pakistan, Russia, South Korea (App Store only), Syria, Türkiye (App Store only), Venezuela, and certain small-island territories. The authoritative list for your region is the regional Apple App Store or Google Play Store listing. EU/EEA users are served via Lucilla's appointed EU representative where required by the Digital Services Act.
To comply with Anti-Money Laundering (AML) regulations and prevent financial crime, we collect and monitor extensive transaction data.
For every financial transaction, we automatically collect:
We collect this data to:
We use automated systems to make real-time decisions about your transactions:
Your Rights: You have the right to contest automated decisions by contacting our compliance team at s.borjas@lucilla.ca. We will review flagged transactions manually upon request.
Transaction data is stored in multiple locations for compliance and operational purposes:
Transaction data is retained for 7 years as required by the Bank Secrecy Act (31 CFR 1010.430). This includes:
Note: Even if you delete your account, transaction data will be retained for the full 7-year period to comply with federal law.
We may share your transaction data with:
We do NOT:
We employ the following automated monitoring technologies:
While compliance data must be retained, you have rights regarding other personal data:
Limitations: We cannot delete transaction data before the 7-year retention period, modify blockchain records (which are immutable), or remove data subject to active investigations.
Transaction data is protected by:
Our mobile app may use:
We do not use cookies for advertising purposes. Our web properties (lucilla.app, enterprise dashboard) may use essential cookies for authentication and session management.
Lucilla includes user-generated content (UGC) in the form of social feed posts, chat messages in 1v1/duo/squad match rooms, social rooms and live spaces, profile media, music reward uploads, business reviews, and reward-card customizations. We operate the following layered moderation system:
Before a post, chat message, or music upload is published we run automated filters that block:
Every post and profile has a Report button that lets any user submit a report with one of these categories: spam, harassment, hate speech, violence or threats, nudity or sexual content, illegal activity, self-harm, scam or fraud, misinformation, or other.
Reports are stored immutably and reviewed by our moderation team. The reporting system is rate-limited (no more than 20 reports per user per 24 hours) to prevent coordinated brigading.
Every profile has a Block button. Blocking another user hides their posts, severs any follow relationship in both directions, and prevents direct messaging. Blocks are bilateral and enforced server-side.
When you file a report we record your Lucilla account ID, the reported post ID, the reason category, and the timestamp. When you block a user we record the block timestamp and the two account IDs. This data is retained for the life of the account and deleted on account deletion. Appeals for moderation decisions may be sent to social@lucilla.ca.
We may update this Privacy Policy periodically. We will notify you of significant changes via email or in-app notification. Continued use after changes constitutes acceptance.
For questions about this Privacy Policy, GDPR / PIPEDA / CCPA rights requests, and data-deletion requests:
For abuse reports, UGC moderation, and in-app support: social@lucilla.ca.
To exercise any of your data rights, contact us at the email above. We will respond within 30 days (or 45 days for CCPA requests).