Lull Privacy Notice Draft

Draft document. This page is a working draft produced for planning. It has not been legally reviewed, is not yet in force, and must not be relied on. Items marked [CONFIRM] await the technical data map.

Status: Draft, not yet in force
Last updated: [CONFIRM date]
Version: 0.1-draft
Owner: [CONFIRM owner]
Legal review: Not yet reviewed

Technical information required before this document can be finalised

Legal entity name, registered address and company number
Privacy contact address
Full list of data collected (your chosen wake and bed times, routine preferences, and reflections)
Whether data remains on the device or is synced to cloud services
Hosting provider and server locations
Authentication, analytics, crash-reporting and notification providers
Retention and backup periods
Account deletion and data export processes
Legal basis for each processing activity, and international transfer safeguards
Position on health-related (special category) data and children's data

Lull is being developed with privacy and user control as core considerations. Full details will appear in this notice before launch.

1. Who we are

[CONFIRM legal entity], [CONFIRM registered address], company number [CONFIRM], operates Lull ("we", "us"). Privacy contact: [CONFIRM privacy email].

2. What this notice covers

This notice will explain what information Lull collects, why, where it is stored, how long it is kept, who (if anyone) it is shared with, and the choices and rights you have. It applies to Lull only; other Beam apps have their own notices.

3. Information we collect

[CONFIRM, awaiting technical data map.] This section will list account information (if any), your chosen wake and bed times, routine preferences, and reflections, and technical information such as crash reports, each with its purpose and legal basis.

4. Where your information lives

[CONFIRM, on-device vs cloud storage, hosting provider, and server locations have not been verified. No claims are made here until they are.]

5. How long we keep it

[CONFIRM retention and backup periods.]

6. Sharing

[CONFIRM third-party processors and any sharing between Beam apps.]

7. Your rights and choices

You have rights under UK data protection law, including access, correction, deletion, and portability. How to exercise each of these in Lull will be documented here, including account deletion and data export. [CONFIRM processes]

8. Children

[CONFIRM minimum age and children's data position.]

9. Changes and complaints

We will update this notice before launch and note material changes here. You can complain to the Information Commissioner's Office (ico.org.uk) at any time.