Privacy Policy
This Privacy Policy explains how VEDMI TECHNOLOGY LTD, doing business as LuckyLove ("LuckyLove", "we", "us", or "our"), collects, uses, stores, discloses, and otherwise processes personal data when you use luckylove.ai, our websites, applications, online services, AI Companions, and related features (collectively, the "Services").
We take the privacy and security of our users seriously. Because LuckyLove provides AI Companion services that may involve private conversations, long-term memory, AI-generated media, voice interactions, and adult-oriented content, we apply particular care to the handling of personal and potentially sensitive information.
This Privacy Policy should be read together with our Terms of Service, Cookie Policy, Content Moderation Policy, AI Transparency Notice, and other policies made available through the Services.
1. Who We Are
The data controller responsible for your personal data is:
Legal entity: VEDMI TECHNOLOGY LTD
Trading name: LuckyLove / LuckyLove AI
Registration number: HE498119
Registered office: Omonoias, 12, Strovolos, 2008, Nicosia, Cyprus
Country: Cyprus
Privacy contact: [email protected]
If you have any questions, comments and/or requests regarding this Privacy Policy or wish to obtain more details in relation to the personal data we process about you, please contact us by sending an email to [email protected].
2. Scope of This Policy
This Privacy Policy applies to personal data processed when you:
- visit our websites;
- create or use a LuckyLove account;
- communicate with AI Companions;
- create or configure AI Characters;
- use text, image, video, audio, or voice features;
- use long-term memory or personalization features;
- purchase Coins, subscriptions, or other paid Services;
- contact customer support;
- report content or submit a complaint;
- submit a privacy request;
- participate in surveys or other optional activities;
- interact with our emails, marketing communications, or other communications; or
- otherwise interact with the Services.
3. Our Adult-Only Service
LuckyLove is an adult-oriented service. You must be at least 18 years old, or older where a higher minimum age applies under the law of the jurisdiction from which you access the Services.
We do not knowingly provide the Services to minors. If we become aware that a person below the applicable minimum age has accessed the Services or provided personal data to us, we may suspend or terminate the relevant account and take appropriate steps to delete or otherwise handle the associated data in accordance with applicable law.
If you believe that a minor has provided personal data to us, please contact us immediately at [email protected].
4. What Personal Data We Collect
Depending on how you use the Services, we may process the following categories of personal data.
4.1 Account and registration data
This may include:
- email address;
- account identifier;
- username or display name;
- password or authentication information;
- account creation date;
- account status;
- subscription status;
- preferences and settings.
4.2 Conversation and interaction data
When you use LuckyLove AI Companions, we may process:
- messages and prompts you submit;
- conversation history;
- instructions and requests;
- AI Character configurations;
- interaction history;
- generated responses;
- information contained in conversations;
- safety and moderation signals associated with interactions.
Your private conversations are not routinely read by our staff. They are processed primarily by automated systems.
Human access may occur only in the limited circumstances described in our Terms of Service and applicable policies, including where necessary for certain serious safety issues, legal obligations, account appeals, security incidents, fraud investigations, or abuse investigations.
4.3 Memory and personalization data
If you use a feature that allows LuckyLove to remember information about your interactions, we may process information used to provide that feature, including:
- preferences;
- facts you choose to share;
- conversation-related information;
- personalization settings;
- AI-generated memory entries.
You may be able to review, modify, or delete available memory information through the Services where those controls are provided.
4.4 Generated content
Depending on the features you use, we may process:
- AI-generated text;
- AI-generated images;
- AI-generated video;
- AI-generated audio;
- voice interactions;
- prompts used to generate media;
- technical information associated with generated content.
4.5 Payment and transaction information
When you make a purchase, we may receive information such as:
- transaction identifier;
- payment status;
- amount;
- currency;
- product or subscription purchased;
- transaction date;
- billing country;
- limited payment information made available by the payment provider.
Payment processing may be performed by third-party payment providers. We do not intend to store full payment-card credentials where those credentials are processed directly by the relevant payment provider.
Payment providers may process your personal data under their own privacy policies.
4.6 Technical and security information
We may process:
- IP address;
- browser type;
- operating system;
- device information;
- device identifiers;
- approximate location derived from IP address;
- timestamps;
- session information;
- authentication information;
- logs;
- security events;
- error reports;
- performance information.
4.7 Age-assurance information
Because LuckyLove is an adult-only service, we may process information necessary to establish or confirm that you satisfy the applicable age requirement. Depending on the age-assurance method used, this may include:
- age-confirmation information;
- age-verification status;
- verification token or reference;
- information returned by an age-verification provider.
Where possible, we seek to minimize the information retained by LuckyLove and retain only the information necessary to demonstrate or enforce age eligibility.
4.8 Customer support information
If you contact us, we may process:
- your email address;
- account information;
- communications with us;
- attachments you provide;
- information necessary to investigate and resolve your request.
4.9 Moderation and safety information
We may process information necessary to:
- detect prohibited content;
- prevent abuse;
- protect users;
- detect fraud;
- investigate security incidents;
- enforce our Terms and Policies;
- comply with legal obligations;
- respond to lawful requests from authorities.
Moderation is primarily automated. Human review may occur only in the circumstances described in our Terms of Service and applicable policies.
4.10 Information received from third parties
We may receive personal data from:
- payment providers;
- authentication providers;
- age-assurance providers;
- fraud-prevention providers;
- security providers;
- analytics providers;
- customer-support providers;
- other service providers;
- law-enforcement or regulatory authorities where legally permitted or required.
5. Special Categories of Personal Data
Some information that users voluntarily provide in conversations may reveal information belonging to special categories of personal data under Article 9 of the GDPR, including information concerning a person's health, sex life, or sexual orientation.
We do not require you to disclose such information in order to use the Services. You should avoid providing sensitive personal information that is not necessary for your use of the Services.
Where our processing involves special-category personal data, we process that information only where an applicable condition under Article 9 of the GDPR permits the processing. Where explicit consent is required, we will obtain that consent separately and in a manner that is specific, informed, and capable of being withdrawn.
Acceptance of our Terms of Service is not itself intended to constitute consent to processing for purposes for which separate consent is legally required.
6. How We Use Personal Data
We may use personal data for the following purposes:
Providing the Services
- to create and manage your account;
- to authenticate you;
- to provide AI Companion functionality;
- to process prompts and generate responses;
- to provide requested images, video, audio, and other media;
- to provide memory and personalization features;
- to maintain your account and preferences.
Payments
- to process purchases;
- to provide subscriptions;
- to process Coins transactions;
- to verify payment status;
- to prevent fraudulent transactions;
- to manage refunds and chargebacks;
- to maintain financial and accounting records.
Safety and moderation
- to detect prohibited content;
- to prevent abuse;
- to protect minors;
- to protect users and third parties;
- to investigate serious violations;
- to enforce our Terms and Policies;
- to respond to reports;
- to investigate fraud and security incidents.
Security
- to protect accounts;
- to detect unauthorized access;
- to prevent attacks;
- to detect abuse;
- to maintain system integrity;
- to investigate security incidents.
Legal compliance
- to comply with applicable laws;
- to respond to lawful requests;
- to preserve evidence where legally required;
- to establish, exercise, or defend legal claims;
- to comply with court orders or regulatory requirements.
Customer support
- to respond to questions;
- to investigate problems;
- to resolve complaints;
- to process privacy requests;
- to administer appeals.
Service analytics and improvement
We may use technical, usage, aggregated, or appropriately anonymized information to understand service performance, identify errors, improve reliability, and develop the Services.
We do not use private User Content to train, fine-tune, or evaluate general-purpose or third-party AI models.
7. Legal Bases for Processing
Where the GDPR applies, we rely on one or more of the following legal bases, depending on the specific processing activity:
| Processing purpose | Typical legal basis |
|---|---|
| Account creation and core Services | Article 6(1)(b) — performance of a contract |
| Providing requested AI features | Article 6(1)(b) — performance of a contract |
| Payments and transactions | Article 6(1)(b) and/or Article 6(1)(c) |
| Compliance with legal obligations | Article 6(1)(c) |
| Security and fraud prevention | Article 6(1)(f) — legitimate interests |
| Enforcement of Terms and Policies | Article 6(1)(f) and/or Article 6(1)(c) |
| Customer support | Article 6(1)(b) and/or Article 6(1)(f) |
| Marketing where consent is required | Article 6(1)(a) — consent |
| Non-essential cookies | Consent where required |
| Legal claims | Article 6(1)(f) and/or other applicable legal basis |
Where Article 9 special-category data is processed, an additional Article 9 condition will apply where required.
We do not treat acceptance of our Terms of Service as consent where the GDPR requires a separate consent.
8. AI Processing and Model Training
LuckyLove uses artificial intelligence systems to provide the Services. You are informed whenever you interact with an AI Companion that you are interacting with an AI system.
AI-generated content is fictional and may be inaccurate, incomplete, unexpected, or unsuitable for a particular purpose.
No training of AI models using User Content
Subject to the terms of our Terms of Service, we do not use your private:
- conversations;
- prompts;
- messages;
- memories;
- generated images;
- generated videos;
- generated audio;
- voice interactions;
to train, fine-tune, or evaluate AI models.
This restriction does not prevent us from processing User Content where necessary to provide the Services, perform automated safety and moderation checks, comply with law, maintain security, or perform other processing expressly described in this Privacy Policy.
9. Automated Processing and Moderation
We use automated systems to detect prohibited content, protect the Services, and enforce our safety rules. Automated systems may:
- analyze prompts;
- identify potentially prohibited requests;
- block or modify requests;
- prevent certain outputs;
- restrict access;
- trigger account or content review.
Human review is limited to circumstances described in our Terms of Service and applicable policies.
Where applicable law grants you rights concerning automated decision-making, including rights under Article 22 GDPR, you may exercise those rights by contacting us at [email protected].
10. Who May Receive Personal Data
We may disclose personal data to the following categories of recipients where necessary:
- hosting and infrastructure providers;
- AI model and AI infrastructure providers;
- image, video, audio, and voice providers;
- content moderation providers;
- security and fraud-prevention providers;
- payment providers;
- age-assurance providers;
- analytics providers;
- customer-support providers;
- email and communications providers;
- professional advisers;
- auditors;
- insurers;
- regulators;
- courts;
- law-enforcement authorities where required or legally permitted.
We require processors handling personal data on our behalf to provide appropriate contractual and technical safeguards.
11. International Data Transfers
Some of our service providers may process personal data outside the European Economic Area ("EEA").
Where personal data is transferred outside the EEA, we use an applicable legal transfer mechanism, such as:
- an adequacy decision of the European Commission;
- Standard Contractual Clauses;
- another lawful transfer mechanism permitted under Chapter V GDPR.
Where appropriate, we implement additional safeguards based on the nature and risk of the transfer.
12. Data Retention
We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law.
Retention periods depend on the type of data, the purpose of processing, security requirements, legal obligations, and whether a dispute or legal claim exists.
Our retention schedule is:
| Data category | Retention period / criteria |
|---|---|
| Account information | 30 days after account deletion |
| Conversation history | 30 days after account deletion |
| AI Memory | 30 days after account deletion |
| Generated media | 30 days after account deletion |
| Voice data | 30 days after account deletion |
| Moderation records | 180 days after account deletion |
| Security logs | 30 days after account deletion |
| Age-verification data | 30 days after account deletion |
| Payment/accounting records | 180 days after account deletion |
| Customer support records | 180 days after account deletion |
| Consent records | 180 days after account deletion |
| Cookie/consent data | As described in our Cookie Policy |
When personal data is no longer required, we delete it, anonymize it, or otherwise securely dispose of it, subject to applicable legal and technical limitations.
13. Your GDPR Rights
Where the GDPR applies, you may have the following rights:
- right to be informed;
- right of access;
- right to rectification;
- right to erasure;
- right to restriction of processing;
- right to data portability;
- right to object;
- right to withdraw consent;
- rights concerning automated decision-making and profiling;
- right to lodge a complaint with a supervisory authority.
The availability of a particular right depends on the circumstances and legal basis of the relevant processing.
You may submit a request by contacting: [email protected]
14. How We Handle Privacy Requests
We may take reasonable steps to verify your identity before providing access to personal data or completing certain requests. We do this to prevent unauthorized disclosure of personal information.
We normally respond to GDPR requests without undue delay and, in principle, within one month. Where permitted by law, this period may be extended where a request is complex or numerous. If an extension is required, we will inform you within the applicable period.
Requests are normally handled free of charge, subject to the exceptions permitted by applicable law.
15. Deleting Your Account
Where the Services provide an account-deletion function, you may use that function to request deletion of your account. You may also contact us at [email protected].
Deletion may not result in the immediate deletion of every record where we are required to retain certain information for:
- legal compliance;
- accounting;
- fraud prevention;
- security;
- dispute resolution;
- establishment, exercise, or defence of legal claims.
Where retention is required, we will retain only the information necessary for the applicable purpose and restrict its use accordingly.
16. Security
We implement appropriate technical and organisational measures designed to protect personal data against unauthorized access, accidental loss, destruction, alteration, disclosure, and other unlawful processing.
Depending on the nature of the data and the risk involved, our safeguards may include:
- access controls;
- least-privilege access;
- authentication controls;
- encryption in transit and, where appropriate, at rest;
- logging and monitoring;
- secure development practices;
- service-provider security controls;
- incident-response procedures;
- backup and recovery controls.
No system can be guaranteed to be completely secure.
17. Personal Data Breaches
We maintain procedures for identifying, assessing, containing, documenting, and responding to personal data breaches.
Where required by GDPR or other applicable law, we will notify the relevant supervisory authority and affected individuals within the applicable legal time limits.
18. Children and Minors
The Services are intended exclusively for adults. We do not knowingly collect or maintain accounts for persons who do not satisfy the applicable minimum age.
If we become aware that a minor has accessed the Services, we may suspend the relevant account and take appropriate measures to delete or restrict the processing of associated personal data, subject to legal retention requirements.
19. Direct Marketing
Where permitted by applicable law, we may send service-related communications that are necessary for the operation of your account.
Marketing communications will be sent only where we have an appropriate legal basis. Where marketing is based on consent, you may withdraw your consent at any time.
Every marketing email will provide an appropriate method to unsubscribe or manage your preferences.
20. Cookies and Similar Technologies
We use cookies and similar technologies as described in our Cookie Policy. Non-essential cookies and similar technologies are used only where the required consent has been obtained.
You can manage your preferences at any time through our Cookie Settings.
21. Third-Party Services and Links
The Services may contain links to third-party websites or services. We are not responsible for the privacy practices of third parties.
We encourage you to review the privacy notices of third-party services before providing them with personal information.
22. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. If we make material changes, we will provide an appropriate notice and, where required, obtain any necessary consent.
The "Last Updated" date at the top of this Privacy Policy indicates when the latest version was published.
23. Contact Us
For privacy questions, GDPR requests, complaints, or concerns, contact:
VEDMI TECHNOLOGY LTD
Omonoias, 12, Strovolos, 2008, Nicosia, Cyprus
Privacy, privacy requests and our DPO, if applicable:
24. Right to Lodge a Complaint
If you believe that our processing of your personal data infringes applicable data protection law, you have the right to lodge a complaint with the competent supervisory authority.
You may contact the supervisory authority in the country where you live, work, or where you believe the alleged infringement occurred.
You are not required to contact us before lodging a complaint with a supervisory authority.