Privacy Policy — LUTYO DataProbe Lite

Effective date: 30 September 2025

App: LUTYO DataProbe Lite (“L-DP Lite”)

Company: LUTYO Ltd

Contact: support@lutyo.com

We don’t track who you are. No account. No name. No phone number. No email in the app.

While you drive, the app turns phone signals into anonymous driving stats. Only those stats are sent to our cloud to improve safety models.

We can see that “a drive happened,” but we cannot know who drove it. Driving data received by our servers is anonymous and not linked to personal identifiers. We do not create user profiles.

EU/UK (GDPR/UK GDPR). We rely on your consent on the device for Location and Motion access. We process de-identified/anonymous driving stats under legitimate interests to develop and improve safety technology. If you contact support or request a TestFlight invite, we process that personal information to provide the service and respond to you (contract/consent). You can withdraw device permissions anytime in iOS settings.

United States. We process de-identified data and do not sell data. If you provide personal information (e.g., an email for a TestFlight invite or support), we use it only to provide the service and reply. Where state privacy laws apply (e.g., CA/VA/CO/CT/UT and others), you may have rights to access, delete, or correct information you provided—contact us to exercise them.

Canada (PIPEDA and provincial laws). Driving stats are handled as de-identified/anonymous and are not reasonably linkable to an individual. If you provide personal information (e.g., email for an invite/support), we collect it with your consent and use it only for the stated purposes. You may request access, correction, or deletion of information you provided—contact us.

Notes. We do not link driving location data to names, phone numbers, emails, or accounts. We maintain technical and organizational measures to prevent re-identification and to keep de-identified data separate from any contact information you share with us.

We use reputable cloud providers (e.g., AWS and Microsoft Azure). Data may be processed in your region when feasible. If moved across regions, we apply appropriate safeguards.

Anonymous driving stats are kept only as long as needed for model improvement, testing, and security. Technical logs have short retention windows. Because we do not store personal identifiers, we cannot re-identify a specific tester from driving data.

We don’t sell data.

We share data only with service providers who process it for us (cloud hosting, analytics, security). They must protect it and cannot use it for their own purposes. We may share aggregated, anonymous insights with research or safety partners.

Data in transit and at rest is encrypted. We limit access, monitor systems, and review controls regularly.

You are in control. You can pause a drive, turn off location/motion permissions, or delete the app. If you contact us to delete records, we will remove any associated technical logs we can locate. Fully anonymous drive records generally cannot be linked back to you.

The app is not directed to children. Do not use if you are under the age required by your local laws for this type of testing.

If we change this policy, we will update the “Effective date” and post the new version.

Questions or requests: support@lutyo.com

Note about TestFlight: Access is invite-only. Apple manages invites and tester emails. Your TestFlight email is not stored in the app and is kept separate from any driving data processed by LUTYO.