Privacy Policy

Lura is operated by Fabricio Corrieri Bizonin LTDA, a company registered in Brazil under CNPJ 48.132.405/0001-00, with its registered office at Florianópolis, SC, Brasil ("Lura", "we", "us").

We are the data controller for the personal data described here. For anything in this policy, including requests about your rights, write to privacy@runwithlura.com. That address is also the contact for our data protection officer (Encarregado, under Article 41 of the LGPD).

This policy covers the Lura mobile app and this website. It does not cover services that are not ours, even when you reach them through Lura, such as the App Store, Apple Health, or Garmin Connect. Those have their own policies.

Almost everything Lura holds is something you typed in or a workout you recorded. We do not buy data about you, and we do not collect it from third parties beyond what your sign-in provider tells us.

Cycle, symptom, heart-rate and pain data are sensitive personal data under Article 11 of the LGPD and special category data under Article 9 of the GDPR. We process them only with your explicit consent, which you give when you choose to enter them, and you can withdraw it at any time by deleting the data or your account.

If you allow it, Lura reads workouts, distance, heart rate and active energy from Apple Health, and writes your completed runs back so they appear alongside your other activity. Cycle information is never read from Apple Health: what Lura knows about your cycle is what you typed into Lura.

• We never use HealthKit data for advertising or any use-based data mining, and we never sell it. Apple prohibits this, and so do we.
• We never share HealthKit data with third parties except to provide you with a feature of the app, and never for marketing.
• Health permission is optional. If you decline it, workouts still run with GPS alone.
• You can revoke access at any time in the iPhone Health app, under Sharing.

Lura records your precise location only while a workout is running, so it can measure distance, pace, elevation and your route. Location tracking continues while your screen is off or you switch apps, because a run does not stop when you put your phone in your pocket. iOS shows the blue location indicator the whole time.

Lura does not track your location in the background when you are not running. There is no passive tracking, no geofencing, and no location-based profiling or advertising.

Route data is stored on our servers so your history survives a lost phone. We treat it as sensitive, because the start of a run usually is someone's home: route map images live in a private storage bucket that only you can read, served through short-lived signed links, and they are deleted when you delete the workout or your account.

Lura is an automated coach, so it is only fair to say plainly what it decides on its own.

• It builds a profile of how your body responds in each phase of your cycle, from the effort you report, how each run felt, and any pain you log, and it uses that to make workouts easier or harder for you specifically.
• It sets your weekly distance and progression from your training history.
• It can raise a flag suggesting you may be under-fuelling for your training load, or that something you reported deserves a professional opinion, and it can pause prescriptions until you confirm you are alright.

These decisions affect a training suggestion, not your legal rights, your access to a service, or anything financial. Nothing here is a diagnosis. You are never obliged to follow the plan, you can change your inputs at any time, and you can ask us for a human review of any automated outcome, or contest it, by writing to us. Under Article 20 of the LGPD and Article 22 of the GDPR you have the right to that review, and we will give it.

This section matters more than usual for an app that knows your cycle, so it is a commitment, not a summary.

• We do not sell your personal data, and we do not share it for cross-context behavioural advertising. Not for money, not for anything else.
• We run no advertising in Lura, and no advertising network receives anything from it.
• We use no analytics or crash-reporting service. There is no Google Analytics, Firebase, Sentry, Mixpanel, Amplitude, Segment, or anything comparable in the app.
• We do not access your device's advertising identifier (IDFA), and we never ask you for tracking permission, because we have nothing to track you with.
• We do not use your data to train machine learning models, ours or anyone else's.
• We do not build a profile of you for marketing, and we do not enrich your data with anything bought from a broker.

On requests from authorities: we will not disclose your cycle, symptom or location data in response to an informal request. We require valid, binding legal process, we assess whether it is lawful and proportionate, we disclose the narrowest set of data that answers it, and we will tell you unless we are legally barred from doing so. If we are ever compelled in a way we consider unlawful, we will resist it to the extent the law allows.

We keep the list short on purpose. These are the only companies that handle your data on our behalf, and each one is bound by a contract limiting them to what we ask.

We may also disclose data if the law requires it, subject to the commitment in section 7, or if the business is ever sold or merged, in which case you will be told before your data moves and this policy will continue to apply until you are given a new one.

If you share a run card to Instagram, that is you sending an image to Meta from your own phone, at the moment you tap share. We send nothing to Meta on our own.

Your Lura data is stored in Brazil. Some of the services listed above are in the United States, so data reaches them there.

For transfers out of the European Economic Area or the United Kingdom, we rely on the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum where it applies, and the EU-US and UK-US Data Privacy Framework where the recipient is certified. For transfers out of Brazil, we rely on the mechanisms in Articles 33 to 35 of the LGPD, including contractual clauses and, for the sensitive categories, your specific consent. You can ask us for a copy of the safeguards in place.

We keep your data for as long as your account exists. A cycle app is only useful because it remembers: predictions get better with each cycle you record, and progression is measured against runs from months ago. We would rather tell you that plainly than promise a deletion schedule the product cannot honour.

• You can delete any individual workout, cycle entry, symptom log, community post or comment at any time, and it is gone from our database immediately.
• When you delete your account, we erase your data from our live systems immediately, including your route maps and community attachments. Encrypted backups are rotated out within 30 days.
• We may keep a minimal record of the deletion itself, and of any transaction we are required to keep for tax purposes, with no health, cycle or location data in it.

• Data is encrypted in transit and at rest.
• Every table is protected by row-level security, so a query can only ever return your own rows, enforced by the database rather than by the app asking nicely.
• Route map images are in a private bucket readable only by you, through links that expire.
• Connected-device tokens, such as Garmin's, are stored where no client application can read them at all.
• The community feed is genuinely pseudonymous: posts and comments are served by functions that never return the author's identifier, so other users cannot tell who wrote what, and screenshot filenames carry no link to your account.
• We store no passwords, because sign-in is handled by Apple and Google.

No system is perfect. If a breach ever affects your data in a way that poses a risk to you, we will notify you and the relevant authority, including the ANPD in Brazil and the supervisory authority in the EEA or UK, within the deadlines the law sets.

Wherever you live, you can ask us to do all of the following, and we will not charge you or treat you worse for asking.

• Know what we hold about you, and get a copy of it in a portable format.
• Correct anything that is wrong.
• Delete your account and everything in it. You can do this yourself in the app, under Settings.
• Withdraw your consent, which stops the processing that relies on it from then on.
• Object to processing based on our legitimate interests, and ask for a human to review any automated decision.
• Restrict processing while a dispute about your data is resolved.
• Complain to a regulator: the ANPD in Brazil, your local supervisory authority in the EEA, the ICO in the UK, or your state attorney general in the United States.

The fastest route for deletion is the app itself: Settings, then "Delete my account". For anything else, write to privacy@runwithlura.com. We answer within 15 days for requests under the LGPD and within one month under the GDPR, and we will tell you if we need longer and why. We may need to confirm that the request comes from the account holder, which we do through the email address on the account rather than by asking for more documents than necessary.

Brazil. This policy is written to meet the LGPD. Sensitive data is processed on your explicit and specific consent under Article 11(I). Our data protection officer can be reached at the address in section 1.

United States. We have not sold or shared personal information for cross-context behavioural advertising in the last twelve months, and we do not do so now. We collect the categories described in section 2, including the sensitive categories of precise geolocation and health information, for the purposes in section 5, and we use sensitive information only to provide the service you asked for, never to infer characteristics about you. Under the California Consumer Privacy Act you have the rights to know, delete, correct, and to opt out of sale or sharing, and we do not discriminate against you for exercising them. Residents of Colorado, Connecticut, Virginia, Utah and other states with comparable laws have equivalent rights, exercisable the same way.

Washington My Health My Data Act, and Nevada SB 370. Cycle, symptom, heart-rate and location data are "consumer health data" under these laws. We collect them only with your consent, we do not sell them, and we would require your separate written authorisation to do so, which we will not seek. Washington residents have the right to know which third parties receive their consumer health data, listed in section 8, and the right to have it deleted, which the in-app deletion satisfies.

European Economic Area and United Kingdom. We rely on your explicit consent for health data under Article 9(2)(a). You may lodge a complaint with your local supervisory authority. We have not appointed an Article 27 representative, as our processing does not meet the threshold that requires one; if that changes, this policy will say so before it does.

Lura is for people aged 16 and over. We do not knowingly collect data from anyone younger, and the app will not accept an age below 16. If you believe a child has given us their data, write to us and we will delete the account.

If we change how we handle your data in a way that matters, we will update this page, change the date at the top, and tell you in the app before the change takes effect. If the change requires your consent, we will ask for it rather than assume it.

Questions, requests, or complaints: privacy@runwithlura.com.

Fabricio Corrieri Bizonin LTDA, CNPJ 48.132.405/0001-00, Florianópolis, SC, Brasil.