Privacy Policy – LuxHalo Intelligence

Last Updated: September 7, 2026

Privacy • Trust • Calm Intelligence

LuxHalo Intelligence (“LuxHalo,” “we,” “our,” or “us”) is designed around presence, reflection, and calm technology.

This Privacy Policy explains what information we collect, how we use it, how artificial intelligence services are used within LuxHalo, when we share information with service providers, how we protect and retain information, and the choices and rights available to you.

Where applicable law requires your consent for a particular processing activity, LuxHalo will obtain that consent through the appropriate interface.

Information We Collect

Depending on how you use LuxHalo, we may collect or process:

Name and account information
Email address
Authentication credentials
Profile information
Journal entries, reflections, notes, and related content
Halo conversations and prompts
Voice and audio data processed through Voice features
Transcription data generated during Voice features
AI-generated observations and related Listening data
Subscription and billing information
Device information and diagnostics
Usage and technical analytics
Customer support communications

We collect information directly from you, automatically through your use of LuxHalo, and from authentication, payment, or other service providers you choose to use.

The information collected depends on the features you choose to use.

How We Use Information

We may use information to:

Provide and maintain LuxHalo services
Authenticate users and maintain accounts
Support Halo conversations
Provide Journal functionality
Provide Halo Memory and personalization features
Enable Voice features
Provide Halo Listening and generate requested observations
Deliver Atmosphere experiences
Process subscriptions and payments
Improve service quality, reliability, and performance
Diagnose technical problems
Provide customer support
Detect abuse, fraud, security threats, and misuse
Protect the security and integrity of LuxHalo
Comply with legal obligations
Enforce our Terms and Conditions
Exercise or defend legal claims where necessary

We seek to use information only for purposes that are reasonably related to the services and functionality you request or as otherwise permitted or required by applicable law.

Artificial Intelligence Processing

LuxHalo uses artificial intelligence services provided by OpenAI and other service providers to power certain LuxHalo features, including Halo conversations, journaling assistance, memory-related functionality, and Voice experiences.

When you use AI-powered features, information may be transmitted to our AI service providers as necessary to provide those features.

This may include:

Messages and prompts you send to Halo
Conversation history necessary to provide continuity, memory, or personalization
Journal content that you choose to share with Halo
Voice recordings or audio data captured during Voice interactions
Transcription data generated from Voice interactions
Context necessary to generate requested AI responses or observations

LuxHalo transmits information to AI service providers only as necessary to provide, secure, maintain, or support the applicable functionality and as otherwise permitted or required by applicable law.

LuxHalo does not sell your AI conversation data.

AI service providers may process information according to their applicable agreements, privacy policies, and data-processing terms. Where required by applicable law, LuxHalo takes appropriate steps to establish contractual and other safeguards for information processed by service providers.

Users may be presented with an AI Processing Consent screen before AI-powered functionality becomes available. Where consent is required, AI functionality will be enabled only after the applicable consent has been obtained.

Where available, users may withdraw AI-processing consent through Profile → Privacy → Manage AI Consent. Withdrawing consent may make certain AI-powered features unavailable.

Halo Conversations and Memory

Conversation history may be stored to provide:

Continuity between conversations
Halo Memory functionality
Personalization features
Account-based experiences

You control the information you choose to share with Halo.

You should avoid sharing highly sensitive personal information unless necessary for your intended use of the service.

You retain ownership of content you create within LuxHalo, subject to the rights necessary for LuxHalo to provide the service as described in the Terms and Conditions.

Journal Content

Journal entries, reflections, notes, and related content may be stored to support:

Journal functionality
Continuity
Memory features
Personalization
Account-based experiences

You retain ownership of journal content you create within LuxHalo.

Journal content that you choose to share with Halo may be processed by AI service providers as described in this Privacy Policy.

Voice Features

When you choose to use Voice features, LuxHalo may access your device microphone while the applicable Voice feature is active.

LuxHalo Voice features may include Standard Voice, Live Conversation, and Halo Listening.

Voice features may capture audio containing your voice and, depending on the circumstances, the voices or speech of other people nearby.

Voice features may:

Capture audio through your device microphone while the feature is active
Convert captured audio into text through speech-recognition or transcription services
Transmit audio or transcription data to service providers such as OpenAI for processing necessary to provide the requested functionality
Use processed information to generate AI responses or, for Halo Listening, AI-generated observations

Voice functionality may be disabled through your device settings, although doing so may prevent Voice features from functioning.

Halo Listening

Halo Listening is an optional feature that allows you to intentionally place LuxHalo into a listening session so that Halo can process ambient audio and generate AI-generated observations.

When you initiate a Halo Listening session, the microphone becomes active only after the applicable pre-session confirmation has been completed.

Before a Halo Listening session begins, LuxHalo may require you to confirm that everyone participating in the conversation has consented to the Halo Listening session.

The Halo Listening confirmation is intended to remind you of your responsibility to obtain any consent and provide any notice required by applicable law before capturing another person’s speech.

You are responsible for ensuring that your use of Halo Listening complies with applicable recording, interception, wiretapping, eavesdropping, privacy, and other applicable laws.

Halo Listening may capture speech from people other than the LuxHalo user. LuxHalo does not independently verify whether third parties have provided consent.

Captured audio may be transmitted to OpenAI or other service providers for speech recognition, transcription, and AI processing necessary to generate the requested observations.

Halo Listening is designed to produce AI-generated observations rather than provide the user with a verbatim transcript of the Listening session.

LuxHalo does not intentionally retain raw Halo Listening audio or underlying transcription data after the processing necessary to generate the requested observations is complete, except where retention is necessary for security, legal compliance, service operation, or another purpose disclosed in this Privacy Policy.

The resulting observations and related information may be retained as part of the LuxHalo service according to the applicable feature functionality and your account settings.

Information About Other People

Some LuxHalo features, particularly Voice features and Halo Listening, may incidentally capture information relating to people other than the LuxHalo user.

If you use LuxHalo in circumstances where another person’s speech or other personal information may be captured, you are responsible for providing any notices and obtaining any consent required by applicable law.

LuxHalo does not require people captured incidentally by a user’s microphone to create a LuxHalo account.

Where LuxHalo processes information relating to people who are not LuxHalo users, we seek to process that information only as necessary to provide the requested functionality and as otherwise permitted or required by applicable law.

Subscriptions and Payments

LuxHalo may offer premium subscription services, including LuxHalo Plus.

Subscriptions purchased through Apple are processed by Apple.

Subscriptions purchased through the LuxHalo website may be processed by Stripe or another payment provider made available by LuxHalo.

LuxHalo does not store complete payment card numbers on its own servers.

Payment providers process payment information according to their own privacy policies, security practices, and applicable legal requirements.

Authentication Services

LuxHalo may support authentication through:

Email and password
Sign in with Apple
Google Sign-In
Other identity providers when available

When you choose a third-party authentication provider, certain account information may be shared with or received from that provider according to the provider’s applicable privacy practices.

Cookies, Analytics, and Device Data

LuxHalo may use:

Cookies
Local storage
Device identifiers
Analytics tools
Diagnostic information
Similar technologies necessary to operate and improve the service

These technologies may help us:

Maintain user sessions
Remember preferences
Improve reliability
Understand application usage
Diagnose technical issues
Detect abuse and security threats
Improve service performance

Where required by applicable law, LuxHalo will obtain any required consent for non-essential cookies or similar technologies.

Information Sharing

We do not sell personal information.

We may share information with service providers and other parties where reasonably necessary to operate LuxHalo, provide requested functionality, comply with law, or protect the service.

These parties may include:

OpenAI and other AI service providers
Cloud hosting providers
Database and infrastructure providers
Authentication providers
Payment processors
Analytics and diagnostics providers
Customer support providers
Email and communications providers
Security and fraud-prevention providers
Other service providers assisting in the operation of LuxHalo
Legal authorities or other parties when required or permitted by law

Service providers may process information on our behalf and are expected to maintain appropriate privacy and security protections consistent with their applicable agreements and legal obligations.

We may also disclose information:

To comply with legal obligations, court orders, or lawful governmental requests
To protect the rights, property, safety, or security of LuxHalo, our users, or others
To detect or investigate fraud, abuse, security incidents, or violations of our Terms
In connection with a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction, subject to applicable law

International Data Transfers

LuxHalo is available to users in multiple countries.

As a result, personal information may be processed in countries other than the country in which you reside.

Where required by applicable law, LuxHalo uses appropriate safeguards for international transfers of personal information. Depending on the circumstances, these safeguards may include an applicable adequacy decision, Standard Contractual Clauses, contractual protections, or another legally recognized transfer mechanism.

For users in jurisdictions that impose specific requirements on international transfers, LuxHalo will process and transfer personal information in accordance with those applicable requirements.

The European Commission recognizes Standard Contractual Clauses as one mechanism for transferring personal data from the EU/EEA to third countries, and the European Data Protection Board similarly identifies adequacy decisions and appropriate safeguards such as Standard Contractual Clauses as mechanisms for international transfers.

Data Retention

We retain information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

Provide services
Maintain account functionality
Provide requested features
Maintain security
Detect and prevent abuse or fraud
Comply with legal obligations
Resolve disputes
Enforce agreements
Protect our rights and the rights of others

When information is no longer required, we may delete, anonymize, or aggregate it, subject to applicable legal and operational requirements.

Voice and Listening Data

LuxHalo is designed to minimize retention of transient voice data.

For Halo Listening, raw audio and underlying transcription data are not intentionally retained by LuxHalo after the processing necessary to generate observations is complete, except where retention is necessary for security, legal compliance, service operation, or another specifically disclosed purpose.

The resulting observations and other account-level information may be retained according to the functionality of the service and applicable account settings.

Third-party service providers may have their own applicable retention periods for information processed on LuxHalo’s behalf. Those retention periods may depend on the applicable service, configuration, contractual terms, and legal requirements.

Data Security

We use reasonable technical, administrative, and organizational safeguards designed to protect personal information from unauthorized access, disclosure, alteration, destruction, or misuse.

These safeguards may include access controls, authentication controls, encryption, service-provider security controls, monitoring, and other measures appropriate to the nature of the information and the services we provide.

No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

Your Privacy Rights

Depending on your location and applicable law, you may have rights regarding your personal information, including the right to:

Access information we hold about you
Correct inaccurate information
Request deletion of information
Request restriction of certain processing
Request portability of certain information
Withdraw consent where processing is based on consent
Object to certain processing activities
Opt out of certain activities where applicable
Appeal certain privacy decisions where required by law
Lodge a complaint with a competent data-protection or privacy authority

These rights are subject to applicable legal limitations and exceptions.

Requests may be submitted using the contact information provided below.

We may need to verify your identity before completing certain requests.

California Privacy Rights

California residents may have additional rights under applicable California privacy laws.

Depending on the circumstances, these rights may include rights relating to access, deletion, correction, portability, and certain disclosures or uses of personal information.

LuxHalo does not sell personal information.

Requests regarding California privacy rights may be submitted using the contact information below.

We will process qualifying requests in accordance with applicable California law.

European Economic Area, United Kingdom, and Other Jurisdictions

If you are located in the European Economic Area, United Kingdom, or another jurisdiction with comprehensive data-protection legislation, additional rights and requirements may apply to the processing of your personal information.

Depending on applicable law and the circumstances of processing, LuxHalo may process personal information on the basis of one or more legally recognized grounds, which may include:

Providing and performing the services you request
Your consent
Compliance with legal obligations
Legitimate interests, where permitted by applicable law

Where processing is based on consent, you may withdraw that consent, although withdrawal does not affect processing that occurred before withdrawal.

Where applicable, you may also have the right to lodge a complaint with the data-protection authority in your jurisdiction.

Account Deletion

Users may request deletion of their LuxHalo account through available account settings or by contacting support.

Depending on the account and features used, deletion may result in permanent removal of:

Account information
Journal content
Conversation history
Halo Memory data
Halo Listening observations and related account data
Other information associated with the account

Certain information may be retained where necessary for legal compliance, security, fraud prevention, dispute resolution, enforcement of agreements, or other purposes permitted by applicable law.

Information retained for these purposes will be handled in accordance with applicable legal and privacy requirements.

Children’s Privacy

LuxHalo is not intended for children under 13 years of age.

We do not knowingly collect personal information from children under 13.

If we learn that personal information has been collected from a child under 13 in violation of applicable law, we will take reasonable steps to delete that information.

Where a jurisdiction establishes a higher minimum age for certain processing or requires parental or guardian consent, LuxHalo will comply with applicable requirements.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

Updated versions will be posted on this page with a revised effective date.

If we make material changes to the way we collect, use, disclose, or otherwise process personal information, we may provide additional notice through LuxHalo, our website, email, or another appropriate method where required by applicable law.

LuxHalo Intelligence

Email: support@luxhalo.net

Website: luxhalo.net

Privacy Requests: support@luxhalo.net

If you have questions regarding this Privacy Policy, our privacy practices, AI processing, Voice features, Halo Listening, data rights requests, or account deletion requests, please contact us at the address above.