Privacy Policy

Xalara LLC(“Xalara,” “we,” “us,” or “our”) operates mobile applications available through the Apple App Store. This Privacy Policy describes how we collect, use, store, and protect your personal information when you use our applications, including Lunara, Focara, and any other applications published by Xalara LLC.

We are committed to protecting your privacy and handling your data with transparency and care. This policy applies to all users of our applications and our website at any time they access or use our services. By using our apps, you agree to the collection and use of information in accordance with this policy.

We encourage you to read this policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with this policy or any part of it, please do not use our applications or services. If you have questions about anything described here, please contact us using the information provided in the “Contact Us” section at the end of this document.

We collect only the information necessary to provide and improve our services. The types of information we may collect fall into the following categories:

We do not collect precise location data, access your contacts, read your photos or media library, or access your microphone or camera unless a specific app feature explicitly requires it and you have granted the relevant system permission. You will always be asked before any such permission is requested.

We use the information we collect for limited, clearly defined purposes. We do not use your data in ways that would be unexpected given the context in which it was collected. Specifically, we use your information to:

• Provide and maintain our services: Core app functionality depends on storing and processing the data you enter. Without this, the app cannot work as intended.
• Improve the user experience: Aggregated usage analytics help us understand which features are most valuable, identify friction points, and prioritize development efforts.
• Fix bugs and improve stability: Crash reports and diagnostic data allow us to identify and resolve technical issues quickly, resulting in a more reliable product for all users.
• Respond to support requests: When you contact us, we use the information you provide to answer your question or resolve your issue as effectively as possible.
• Send communications: We may send important service-related notifications (e.g., changes to this policy or critical security updates). Marketing communications are only sent with your explicit prior consent and can be opted out of at any time.
• Ensure security and prevent fraud: We analyze certain patterns to detect and prevent unauthorized access, abuse, or other potentially harmful activity.
• Comply with legal obligations: In limited circumstances, we may be required to process your data to fulfill legal obligations, respond to lawful government requests, or enforce our terms.

To operate our apps effectively, we work with a small number of trusted third-party service providers. We share only the minimum data necessary for each provider to fulfill their specific function, and we do not authorize any third party to use your data for their own independent purposes.

• Apple Analytics: We may use Apple’s built-in analytics platform to receive aggregated, privacy-preserving metrics about app performance and usage. Apple collects this data under their own privacy framework; you can review Apple’s Privacy Policy for details on how they handle that information.
• Cloud infrastructure: Where applicable, user data may be stored using reputable cloud providers operating in the United States. These providers are contractually bound to protect your data and may not use it for their own purposes.
• Crash reporting: We may use automated crash reporting tools to receive anonymous diagnostic reports when an app crashes. No personally identifiable information is included in these reports.

We do not integrate any third-party advertising SDKs, ad networks, or data brokers into our applications. You will never see targeted or behavioral advertisements served through our apps.

We do not sell, rent, or trade your personal information to any third party for their commercial benefit. We treat your data as confidential. The limited circumstances under which we may disclose your information are:

• Service providers: We share data with third-party vendors only to the extent necessary for them to perform services on our behalf (e.g., cloud hosting, crash reporting). These vendors are bound by data processing agreements and are prohibited from using your data for any other purpose.
• Legal requirements: We may disclose your information if required to do so by law, court order, or other binding legal process, or if we believe in good faith that disclosure is necessary to protect our legal rights, prevent fraud, or respond to a government request.
• Business transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via a prominent notice on our website or within our apps before your information becomes subject to a different privacy policy.
• With your explicit consent: We may share your information with other parties when we have your clear, informed, and voluntary consent to do so.
• Protection of rights: We may disclose information when we believe it is necessary to investigate, prevent, or act regarding illegal activities, suspected fraud, or situations involving potential threats to the safety of any person.

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by applicable law. The specific retention period depends on the type of data and the reason it was collected.

• Account and user data: Retained for the duration of your account relationship with us, and deleted within 30 days of an account deletion request.
• Support communications: Retained for up to 2 years to allow for follow-up and to improve the quality of our support, after which they are deleted or anonymized.
• Crash reports and diagnostic logs: Retained for up to 90 days, after which they are automatically purged from our systems.
• Aggregated analytics: Anonymized, aggregated data that cannot be used to identify individuals may be retained indefinitely for trend analysis and product improvement.

To request deletion of your account and associated personal data, please email us at [email protected] with the subject line “Data Deletion Request” and the app name and account details. We will confirm deletion within 30 days.

We take the security of your personal information seriously and implement industry-standard technical and organizational measures to protect it from unauthorized access, alteration, disclosure, or destruction.

• Encryption in transit: All data transmitted between our apps and our servers is encrypted using TLS (Transport Layer Security).
• Encryption at rest: Sensitive data stored on our servers is encrypted at rest using AES-256 or equivalent industry-standard algorithms.
• Access controls: Access to personal data within our organization is restricted on a need-to-know basis. We use strong authentication practices and review access permissions regularly.
• Regular security reviews: We periodically review our security practices, infrastructure configurations, and dependencies to identify and address potential vulnerabilities.

While we strive to protect your information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security. In the event of a data breach that affects your personal information, we will notify you promptly in accordance with applicable law.

Our applications are not directed at children under the age of 13, and we do not knowingly collect personal information from children under 13. We comply with the Children’s Online Privacy Protection Act (COPPA) and equivalent regulations in other jurisdictions.

If we become aware that we have inadvertently collected personal information from a child under 13 without verified parental consent, we will take immediate steps to delete that information from our systems. If you are a parent or guardian and believe your child has provided personal information to us, please contact us immediately at [email protected] with the subject line “COPPA — Child Data Inquiry” and we will act swiftly to investigate and delete the data.

If you are between 13 and 18 years of age, we encourage you to review this Privacy Policy with a parent or guardian before using our applications. Some features may not be appropriate for all age groups, and parental guidance is recommended.

Depending on your location, you may have certain rights regarding your personal information. We respect these rights and will respond to valid requests in a timely manner.

• Right to access: You may request a copy of the personal information we hold about you, including information on how it is used and with whom it is shared.
• Right to correction: If the information we hold about you is inaccurate or incomplete, you have the right to request that we correct it.
• Right to deletion: You may request that we delete your personal information, subject to certain legal obligations that may require us to retain some data.
• Right to opt out: You may opt out of any marketing communications we send at any time by following the unsubscribe instructions in the message or by contacting us directly.

California Residents — CCPA Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know: The right to know what personal information we collect, use, disclose, and sell about you.
• Right to delete: The right to request deletion of personal information we have collected from you, subject to certain exceptions.
• Right to opt out of sale: We do not sell your personal information. However, you retain the right to direct us not to sell it at any time, should our practices ever change.
• Right to non-discrimination: You have the right not to receive discriminatory treatment for exercising your CCPA privacy rights.

To exercise any of these rights, please email us at [email protected] with the subject line “Privacy Rights Request” and a description of your request. We will verify your identity and respond within 30 days.

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the features of our applications. When we make material changes, we will notify you by updating the “Last updated” date at the top of this page and, where appropriate, by displaying a notice within our apps or on our website.

For significant changes that materially affect how we handle your personal information, we may provide more prominent notice, such as an in-app alert or an email notification (if you have provided your email address). We encourage you to review this policy periodically to stay informed about how we are protecting your information.

Your continued use of our applications after any changes to this Privacy Policy constitutes your acceptance of the updated policy. If you do not agree with the revised terms, you should stop using our applications and, if applicable, request deletion of your data as described in the “Data Retention” section above.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way we handle your personal information, we encourage you to reach out to us. We take every inquiry seriously and will do our best to respond promptly and helpfully.

You can contact us by email at [email protected]. Please include a clear subject line (e.g., “Privacy Policy Question,” “Data Deletion Request,” or “Privacy Rights Request”) so we can route your message to the right person as quickly as possible.

Our mailing address is:

We aim to respond to all privacy-related inquiries within 5 business days. For formal rights requests (access, deletion, correction), we will respond within 30 days as required by applicable law.