Tluma AI Translator

1. Introduction

This Privacy Policy describes how Tluma AI ("we", "our", or "us") collects, uses, and discloses your information when you use our mobile application (the "App") and related services. We are committed to protecting your privacy and ensuring you have control over your data.

By using the App, you agree to the collection and use of information in accordance with this policy. This policy is designed to comply with the General Data Protection Regulation (GDPR) and other applicable privacy laws.

2. Data Controller

The data controller for the information collected through the App is:

Tluma AI Developer
Czech Republic
Email: ev.tluma@gmail.com

3. Information We Collect

We collect the following types of information to provide and improve our Service:

A. Information You Provide

• Translation Content: Text and audio/voice data that you input into the App for translation. This content is processed by our servers and third-party AI providers to generate translations.
• Feedback and Reports: Information you provide when you report an issue or send feedback (e.g., "Inaccurate translation"), which may include the source text and the translation.

B. Automatically Collected Information

• Device Identifiers: We generate and store a unique anonymous Device ID to manage your free usage limits and subscription status without requiring you to create an account.
• Location Data: With your permission, we collect your precise or approximate location to provide the "Guide" feature (finding nearby places and recommendations). This data is processed only when you use the feature and is not stored permanently on our servers.
• Usage Data: We collect anonymous data about how you use the App, such as the number of translations performed, language pairs used, and error logs.
• Purchase Data: If you purchase a Premium subscription, we receive a receipt validation token from Google Play or Apple App Store. We do not have access to your credit card or financial details.

4. Legal Basis for Processing (GDPR)

We process your personal data under the following legal bases:

• Contractual Necessity: To provide the translation services and Premium features you have requested.
• Legitimate Interests: To improve our App, prevent fraud/abuse, and ensure security.
• Consent: For optional features or specific data collection where required (e.g., crash reporting).

5. How We Use Your Information

• To provide, operate, and maintain the App.
• To process your translations using AI technology.
• To provide location-based recommendations in the "Guide" feature.
• To manage your subscription and enforce usage limits.
• To detect, prevent, and address technical issues and abuse.
• To improve our AI models and translation quality (using anonymized data).

6. Data Sharing and Third Parties

We do not sell your personal data. We share data with the following third-party service providers solely to operate the App:

• Google Cloud Platform (GCP): We use GCP (Cloud Run, Firestore) to host our backend infrastructure and store data securely.
• Google Gemini (Generative AI): We use Google's Gemini API to generate translations. Data sent to the API is used for generating the response and is subject to Google's Generative AI Data Governance Policy.
• Google Play & Apple App Store: We use these platforms to process payments and manage subscriptions.

7. Data Retention

We retain your data only for as long as necessary to fulfill the purposes outlined in this policy:

• Translation History: By default, we do not store your translation history on our servers. You may choose to save your translation history locally on your device using the "Save History" feature. This data remains on your device and is under your control.
• Temporary Processing: Input text and audio are processed in real-time and are not retained by us after the translation is generated, except for short-term caching to improve performance or for debugging purposes (up to 30 days).
• Device ID & Subscription Data: Retained as long as you use the App to maintain your Premium status.

8. Your Data Protection Rights

Under GDPR and other privacy laws, you have the right to:

• Access: Request a copy of the data we hold about you (linked to your Device ID).
• Deletion: Request deletion of your data from our servers. You can also reset your identity by clearing the App's data or reinstalling it.
• Rectification: Correct inaccurate data.

To exercise these rights, please contact us at ev.tluma@gmail.com. Please include your Device ID (found in the "About App" section) so we can locate your data.

9. Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13.

10. Changes to This Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

1. Agreement to Terms

By downloading, installing, or using Tluma AI, you agree to be bound by these Terms of Service. If you do not agree to these terms, do not use the App.

2. Use License

We grant you a personal, non-exclusive, non-transferable, revocable license to use the App for your personal, non-commercial purposes, subject to these Terms.

3. AI Services and Disclaimer

The App uses artificial intelligence (Google Gemini) to provide translations. You acknowledge that:

• AI translations may not always be 100% accurate, complete, or contextually correct.
• You should not rely solely on the App for critical situations (e.g., medical, legal, or safety-critical communications).
• The Service is provided "AS IS" and "AS AVAILABLE" without warranties of any kind.

4. User Restrictions

You agree not to:

• Use the App for any illegal purpose or to generate harmful content.
• Attempt to reverse engineer, decompile, or disassemble the App.
• Bypass or manipulate the usage limits or subscription mechanisms.
• Use the App to transmit viruses, malware, or other malicious code.

5. Subscriptions and Sponsored Content

Some features of the App may require a Premium subscription. Payments are processed by Google Play or Apple App Store.

The "Guide" feature and other AI recommendations may occasionally include sponsored content or partnerships. Such recommendations are integrated to provide relevant local suggestions. We strive to ensure all recommendations remain useful and high-quality.

6. Limitation of Liability

To the maximum extent permitted by law, Tluma AI and its developers shall not be liable for any indirect, incidental, special, consequential, or punitive damages resulting from your use of or inability to use the App.

7. Governing Law

These Terms shall be governed by and construed in accordance with the laws of the Czech Republic, without regard to its conflict of law provisions.