Lula AI Privacy Policy

In short

Lula AI helps parents and adult guardians create personalized stories for children. To provide the service, we process account and device information, child profile details entered by an adult, story preferences and generated content, and—only when an adult chooses to provide them—photos and voice recordings. We share the minimum information needed with service providers that generate stories, images, and audio; host our infrastructure; deliver notifications; and manage App Store subscriptions.

We do not sell personal information or use child data for advertising. Lula AI is intended to be set up and operated by an adult, not used by a child to create an account or submit personal information independently.

This Privacy Policy explains what we collect, why we use it, who receives it, and the choices available to you.

1. Who we are

Lula AI is provided by Horus Teknoloji ve Dijital Hizmetler, operating as Horus Studios ("Horus," "we," "us," or "our"). Horus is the controller of personal information processed through Lula AI, except where another company acts as an independent controller under its own privacy notice.

Contact: hello@horusstudios.com
Address: Altıntepe Mahallesi, İstasyon Yolu Sokak, No: 3/1, Maltepe, Istanbul, Türkiye

2. Who Lula AI is for

Lula AI is a parent- and guardian-operated service for creating stories for children. The person creating and managing an account must be at least 18 years old or the age of legal majority where they live.

If you add information about a child, you confirm that you are the child's parent or legal guardian, or that you otherwise have the legal authority and any consent required to provide that information and authorize its processing as described in this Policy. Please provide only the information reasonably necessary to personalize the service.

We do not knowingly allow children to create accounts or submit personal information without adult involvement. If you believe a child has provided information to us without appropriate authorization, contact us so that we can investigate and take appropriate action.

3. Information we process

Depending on the features you use, we may process the following categories of information.

Account, installation, and contact information

• A Lula AI user identifier and installation or device identifier.
• Device authentication credentials stored in protected or hashed form.
• Your name, email address, and profile image if you choose to provide them or they are made available through an authorized sign-in method.
• Notification tokens and notification preferences.

Child profile information provided by an adult

• The child's name or nickname, gender, age group, and preferred language.
• Optional developmental considerations or other information that may reveal health-related or sensitive characteristics.
• An optional child photo used to personalize story artwork.

Voice and audio information

• A voice name, language, type, and status.
• An optional voice recording used to create personalized narration or a synthetic voice.
• Technical voice-provider identifiers and generated story audio.

A voice recording may be biometric or sensitive information under some laws, even though Lula AI does not use it to identify or authenticate a person. Do not upload another person's voice unless you have their clear permission and legal authority to do so.

Story information and user content

• Story choices such as theme, characters, educational goal, side characters, creativity, complexity, and sleep settings.
• Prompts, story titles and text, narration text, cover images, personalized images, audio, and other generated output.
• Sharing tokens or links when you use a sharing feature.

Usage and interaction information

• Onboarding steps, feature selections, story plays, listening completion, ratings or feedback, and other product interactions.
• Usage quotas, balances, rewards, and generation history.
• Dates, times, language settings, app version, and similar technical events.

Subscription and transaction information

• Product, plan, entitlement, subscription status, renewal status, purchase and expiration dates, and transaction references.
• Subscription events such as renewal, cancellation, refund, or billing issues.

Payments are processed by Apple. We do not receive or store your full payment-card details.

Technical, security, and diagnostic information

• IP address, user agent, request metadata, server logs, rate-limit events, error details, and security events.
• Device and app identifiers and limited device information made available by our subscription, notification, analytics, or infrastructure providers.

4. How we receive information

We receive information:

• Directly from the adult using Lula AI.
• Automatically from the app, device, and our servers when the service is used.
• From Apple and our subscription-management provider when a purchase or subscription event occurs.
• From artificial-intelligence, image, voice, storage, notification, and hosting providers when they return generated output or service events.

5. Why we use information

We use information to:

• Create and secure your account or app installation.
• Create personalized stories, illustrations, narration, and voice experiences.
• Save your child profiles, voices, story library, progress, and preferences.
• Process subscriptions, apply entitlements, restore purchases, and prevent fraud.
• Send service notifications you have enabled, such as a notice that a story is ready.
• Operate, troubleshoot, secure, and improve Lula AI.
• Measure feature use and understand product performance.
• Provide support, respond to requests, and enforce our Terms of Use.
• Comply with law and protect users, Horus, and others.

Where applicable law requires a legal basis, we rely on one or more of the following: performing our contract with you; your consent or explicit consent; compliance with a legal obligation; and our legitimate interests in operating, securing, supporting, and improving the service, where those interests are not overridden by your rights. You may withdraw consent at any time, but withdrawal does not affect processing already carried out lawfully and may make an optional feature unavailable.

6. Artificial intelligence and voice processing

Lula AI uses third-party services to generate or transform stories, images, narration, and voices. The information sent depends on the feature:

• Story generation: child profile details selected by the adult, story preferences, language, and technical request identifiers may be sent to Wiro AI and model providers available through Wiro, which may currently include models provided by xAI.
• Image generation: story text or summaries, child profile details, and an optional child photo may be sent through Wiro to image-model providers, which may currently include Google models.
• Narration and personalized voices: story text, language, voice settings, and an optional voice recording may be sent to Wiro, Fish Audio, or ElevenLabs, depending on the feature and service configuration.

These companies process information to fulfill our requests and may also process technical information for security, abuse prevention, billing, and service operation. Their retention and use of inputs and outputs—including any use to maintain or improve their services—depends on the provider, our service configuration, and the applicable agreement and privacy notice. Please do not provide optional photos, voice recordings, or sensitive child information unless you are comfortable with this processing.

Horus does not use child profile information, photos, or voice recordings to train its own general-purpose artificial-intelligence models, and we do not permit their use for advertising.

Provider notices include:

• Wiro Privacy Policy
• Fish Audio Privacy Policy
• ElevenLabs Privacy Policy

7. When we share information

We may disclose information to:

• AI, image, and voice providers described above, to generate requested content.
• Cloud and storage providers, including Cloudflare, to host databases, media, generated content, and service infrastructure.
• Subscription providers, including Adapty and Apple, to process purchases and manage access to paid features.
• Notification and app infrastructure providers, including Apple Push Notification service and Expo, to deliver notifications and operate app services.
• Technical service providers that help with hosting, logging, security, customer support, and service maintenance.
• Professional advisers, authorities, or other parties when reasonably necessary to comply with law, enforce agreements, protect safety and rights, investigate fraud or abuse, or complete a merger, financing, reorganization, or sale of all or part of our business.

Our principal provider notices include the Cloudflare Privacy Policy, Adapty Privacy Policy, Expo Privacy Policy, and Apple Privacy Policy.

We do not sell personal information. We do not use child information for targeted advertising. We do not knowingly share personal information for cross-context behavioral advertising.

8. Storage, links, and international transfers

Information may be stored in our database and object-storage systems. Child photos, voice recordings, generated covers, and generated audio may be delivered through unique media URLs. A person who obtains one of these URLs may be able to access the associated media, so do not publish or forward a media or story-sharing link unless you intend to share its contents.

We and our providers may process information in Türkiye, the United States, the European Economic Area, and other countries where we or they operate. Those countries may have different data-protection laws. Where required, we use appropriate contractual or legal safeguards for international transfers.

9. Retention and account deletion

We retain information for as long as reasonably necessary to provide Lula AI, maintain security and integrity, resolve disputes, comply with legal obligations, and establish or defend legal claims. Retention periods vary according to the type of information and the reason it is processed.

You can start account deletion from within the app. Account deletion removes or anonymizes information used to identify the active account and detaches active app references. Some technical, transaction, security, generated-content, and de-identified records may remain where needed for the purposes above. Media objects, provider-side copies, backups, and records required for legal or fraud-prevention purposes may not disappear immediately or automatically.

Removing a voice from the app may first deactivate it and may not immediately erase its recording or a voice created with a third-party provider. To request full deletion of a child profile, photo, voice recording, provider-side voice, generated content, or other personal information, email hello@horusstudios.com. After verifying the request, we will delete or de-identify information that we are not required or permitted to retain and instruct relevant processors where applicable.

Deleting Lula AI or deleting your Lula AI account does not cancel an Apple subscription. Subscriptions must be cancelled through your Apple account settings.

10. Security

We use administrative, technical, and organizational measures designed to protect information, including encrypted network connections, access controls, and protected authentication credentials. No service or storage method can be guaranteed completely secure. You are responsible for protecting access to your device and for sharing story or media links only with people you trust.

11. Your choices and rights

Depending on where you live, you may have the right to:

• Ask whether we process your personal information and request access to it.
• Correct inaccurate or incomplete information.
• Request deletion, anonymization, restriction, or portability.
• Object to certain processing or withdraw consent.
• Learn the recipients or categories of recipients to whom information is disclosed.
• Complain to a data-protection authority, including Türkiye's Personal Data Protection Authority where applicable.

You may also manage photo, microphone, and notification permissions in your device settings; edit or remove information in the app where controls are available; and cancel subscriptions in Apple account settings.

To exercise a privacy right, email hello@horusstudios.com. We may need to verify your identity and authority over child information before completing a request. We will not discriminate against you for exercising a privacy right.

12. Changes to this Policy

We may update this Privacy Policy as Lula AI, our providers, or applicable law changes. We will post the updated version with a new effective date and provide additional notice when required. If a change materially affects consent-based processing, we will request new consent where required by law.

13. Contact us

Questions, complaints, and privacy requests may be sent to:

Horus Studios — Lula AI Privacy
hello@horusstudios.com
Altıntepe Mahallesi, İstasyon Yolu Sokak, No: 3/1, Maltepe, Istanbul, Türkiye