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PRIVACY POLICY

D.M. Lukusa & Lukusa Elite

Effective Date: August 18, 2026
Last Updated: August 18, 2026

This Privacy Policy explains how Dieu Membu Lukusa, trading as D.M. Lukusa ("D.M. Lukusa", "we", "us", or "our") collects, uses, processes, stores, and protects information when you use:

the D.M. Lukusa website, available at dmlukusa.com;
the Lukusa Elite mobile application;
our fitness, wellness, personal-development, digital-content, and related services;
our contact and support services; and
features, links, products, or services made available through our digital platforms.

D.M. Lukusa is based in Abu Dhabi, United Arab Emirates.

For privacy questions or requests, contact:

Email: contact@dmlukusa.com
Website: dmlukusa.com

By using our services, you acknowledge the practices described in this Privacy Policy.

1. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information processed through D.M. Lukusa-operated digital services, including the D.M. Lukusa website and Lukusa Elite.

Some products and services accessible through our platforms are operated by third parties, including app stores, payment providers, affiliate merchants, artificial-intelligence providers, and other service providers.

When you leave our services and interact directly with a third party, that third party's privacy policy and terms may also apply.

2. INFORMATION WE MAY COLLECT

The information we collect depends on which services and features you use.

2.1 Account Information

When you create or use a Lukusa Elite account, we may process information such as:

name or display name;
email address;
account identifier;
authentication information;
account status;
selected language;
app preferences; and
membership or subscription status.

Passwords and authentication credentials may be processed through authentication infrastructure rather than being directly accessible to D.M. Lukusa in readable form.

2.2 Fitness, Wellness and Progress Information

When you choose to use Lukusa Elite's fitness and progress features, you may provide information such as:

height;
weight;
fitness goals;
experience level;
workout activity;
workout progress;
personal exercise records;
habits and habit streaks;
fasting activity;
calorie and macronutrient entries;
water intake;
sleep information;
step information;
heart-rate information where manually entered or otherwise supported;
body measurements;
body-fat information;
progress information; and
other fitness or wellness information you voluntarily enter.

This information is used to provide the features you request.

Lukusa Elite is a fitness and general-wellness service and is not intended to provide medical diagnosis or treatment.

Additional health, fitness, nutrition, fasting, and AI limitations are explained in our separate Health, Fitness, Nutrition & AI Disclaimer.

3. PHOTOS, CAMERA AND IMAGE INFORMATION

Lukusa Elite may request access to your device camera or photo library when you choose to use features that require images.

These may include:

AI Nutrition Scanner

You may choose to photograph or upload an image of food for analysis.

The image may be processed to estimate information such as:

food type;
calories;
protein;
carbohydrates;
fat; and
other nutritional information.

AI-generated nutritional estimates may be inaccurate and should not be treated as medical or professionally prescribed dietary information.

Before & After / Progress Photos

You may choose to add progress photographs to document your fitness journey.

We do not require you to upload progress photographs to use unrelated portions of the service.

Where a feature permits local storage, information may remain on your device. Where cloud functionality is used, information may be processed through the infrastructure necessary to provide that feature.

Camera or photo-library access is requested only where needed for functionality that you choose to use, subject to your device permissions.

4. ARTIFICIAL INTELLIGENCE FEATURES

Lukusa Elite includes or may include AI-powered functionality such as:

Coach Diego;
AI Nutrition Scanner;
AI-generated meal plans;
AI-generated workout plans; and
other personalized fitness or wellness assistance.

When you use an AI feature, information you submit to that feature may be transmitted to an artificial-intelligence service provider to generate the requested response.

This may include text prompts, fitness goals, meal information, workout information, or images when an image-based AI feature is used.

We currently use OpenAI technology for certain AI functionality.

OpenAI states that, by default, inputs and outputs submitted through its API/business offerings are not used to train its models unless the customer affirmatively opts into applicable data-sharing features.

Users should nevertheless avoid submitting unnecessary highly confidential information to AI features.

AI-generated outputs may contain errors and are provided for general informational, fitness, educational, and wellness purposes. They do not replace qualified medical, nutritional, psychological, or other professional advice.

5. WEBSITE INFORMATION AND CONTACT FORMS

When you use dmlukusa.com, we may receive information that you voluntarily submit through forms or communications.

This may include:

name;
email address;
subject;
message content; and
other information you voluntarily provide.

We use this information to:

respond to inquiries;
provide requested support;
communicate about our services;
manage legitimate business communications; and
protect our services against misuse.

Please do not submit sensitive information through a general website contact form unless necessary.

6. SUBSCRIPTIONS AND PURCHASE INFORMATION

Lukusa Elite may offer paid Elite membership or subscription features.

Mobile subscriptions and in-app purchases may be processed through:

Apple App Store;
Google Play; and
subscription-management infrastructure such as RevenueCat.

D.M. Lukusa generally does not receive your complete payment-card details from Apple or Google.

We may receive or process information necessary to determine subscription access, such as:

product or subscription identifier;
entitlement status;
transaction or purchase identifiers;
subscription status;
renewal or expiration information; and
purchase/restoration status.

Actual prices, currencies, billing periods, trial availability where offered, renewals, cancellations, refunds, and payment methods may be controlled or presented by the applicable app store.

7. PAYHIP AND DIGITAL FITNESS PRODUCTS

D.M. Lukusa may offer downloadable fitness programs, guides, meal plans, or other digital products through Payhip.

When you follow a link from dmlukusa.com to Payhip, the purchase is completed using Payhip's platform.

Payhip and applicable payment providers may independently process information required to complete the transaction.

Their respective privacy policies and terms apply to information they process through their services.

D.M. Lukusa may receive information associated with a purchase where necessary to provide purchased products, customer service, transaction records, or other legitimate business functions.

8. AMAZON ASSOCIATES AND AFFILIATE LINKS

D.M. Lukusa participates in affiliate marketing programs, including the Amazon Associates Program.

Our website may contain links to products or services offered by Amazon or other third parties.

If you follow an affiliate link and make a qualifying purchase, D.M. Lukusa may receive a commission at no additional cost to you.

When you follow an external affiliate link, the third-party website may collect information according to its own privacy and cookie practices.

D.M. Lukusa does not control the privacy practices of those external websites.

Please also review our separate Affiliate Disclosure.

9. BOOKS AND THIRD-PARTY RETAILERS

D.M. Lukusa promotes books and publications, including English and French editions.

Links to books may direct users to Amazon or other third-party retailers.

Purchases made through those platforms are processed by the applicable retailer and are subject to that retailer's privacy policy, terms, payment practices, and customer-service procedures.

10. FIREBASE AND CLOUD SERVICES

Lukusa Elite uses or may use Google Firebase services to support functionality such as:

authentication;
user accounts;
application data;
cloud functionality;
security; and
related backend services.

Information processed through Firebase is subject to the applicable Google/Firebase service arrangements and privacy practices.

We configure our services with the intention of limiting access to information to what is necessary for legitimate application functionality.

11. HOW WE USE INFORMATION

We may process information to:

create and manage accounts;
authenticate users;
provide Lukusa Elite functionality;
maintain user preferences;
provide workouts and fitness programs;
provide nutrition and meal features;
operate fasting and habit features;
provide progress tracking;
process AI requests;
provide personalized app functionality;
manage Elite subscription access;
restore purchases;
provide customer support;
respond to contact requests;
provide digital products;
maintain service security;
prevent abuse, fraud, or unauthorized activity;
troubleshoot technical problems;
comply with legal obligations;
establish, exercise, or defend legal claims; and
improve the reliability and functionality of our services where permitted.

We do not sell personal information in the ordinary meaning of selling personal data for monetary consideration.

If our practices materially change, this Privacy Policy will be updated accordingly.

12. LEGAL BASES WHERE APPLICABLE

Depending on your location and the applicable law, we may process information on one or more of the following bases:

your consent;
performance of a contract or provision of a service you request;
compliance with legal obligations;
our legitimate interests in operating, securing, supporting, and improving our services, where those interests are not overridden by applicable rights; and
other lawful grounds available under applicable law.

Where consent is the applicable basis, you may have the right to withdraw that consent, subject to applicable law and the nature of the processing.

13. WHEN INFORMATION MAY BE SHARED

We do not disclose personal information indiscriminately.

Information may be provided to service providers where reasonably necessary to operate a requested service.

Depending on the features you use, these may include providers supporting:

cloud infrastructure and authentication;
artificial intelligence;
subscription management;
app-store transactions;
digital-product sales;
communications;
security; and
technical operations.

Examples may include:

Google/Firebase;
OpenAI;
RevenueCat;
Apple;
Google Play;
Payhip; and
other providers required to deliver functionality you choose to use.

Information may also be disclosed where reasonably necessary to:

comply with applicable law, regulation, court order, or lawful government request;
protect users, D.M. Lukusa, or others;
investigate fraud, abuse, or security incidents;
enforce applicable terms; or
establish, exercise, or defend legal rights.

If the business is reorganized, transferred, merged, or sold, information may be transferred as part of that transaction subject to applicable law.

14. INTERNATIONAL DATA PROCESSING

D.M. Lukusa operates from the United Arab Emirates.

Some service providers used to operate our website and application may process information in other countries.

As a result, information may be processed outside the country where you live.

Where required by applicable law, we seek to use appropriate contractual, organizational, technical, or other safeguards for international processing and transfers.

15. DATA RETENTION

We retain information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing services, maintaining accounts, complying with legal obligations, resolving disputes, preventing fraud, and enforcing agreements.

Retention periods may differ depending on:

the type of information;
whether an account remains active;
the feature being used;
contractual requirements;
security and fraud-prevention requirements; and
applicable legal obligations.

Information stored only on your device may be removed by clearing application data, deleting applicable content, or uninstalling the application, depending on how the particular feature operates.

If you request account deletion, information associated with the account will be deleted or anonymized as applicable, except where limited retention is reasonably necessary or legally required.

16. ACCOUNT AND DATA DELETION

Lukusa Elite users may request deletion of their account and associated personal information.

Where account deletion is available directly inside Lukusa Elite, users may initiate deletion through the applicable account or data-management settings.

We will also maintain an external account-deletion resource at:

dmlukusa.com/account-deletion

You may also contact:

contact@dmlukusa.com

Google Play requires apps supporting account creation to provide both an in-app deletion path and an external web resource for account deletion. Apple likewise requires apps supporting account creation to offer account deletion within the app.

When a valid deletion request is completed, associated account data will be deleted or anonymized as appropriate, subject to information that must legitimately be retained for matters such as legal compliance, transaction records, fraud prevention, security, or dispute resolution.

Additional instructions will be available on our Account & Data Deletion page.

17. YOUR PRIVACY RIGHTS

Depending on where you live and the laws applicable to you, you may have rights concerning your personal information.

These may include the right to:

request access to personal information;
request correction of inaccurate information;
request deletion;
request restriction of certain processing;
object to certain processing;
withdraw consent where processing relies on consent;
request portability where applicable; and
complain to an appropriate data-protection authority.

These rights are not absolute and may be subject to legal exceptions.

To submit a privacy request, contact:

contact@dmlukusa.com

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

18. CHILDREN'S PRIVACY

D.M. Lukusa services and Lukusa Elite are not intended for children under 18, and we do not knowingly seek to collect personal information from children under 18.

Where a higher minimum age or parental-consent requirement applies under local law, users must satisfy that requirement before using services that involve personal information.

If you believe that a child has provided personal information inappropriately, contact:

contact@dmlukusa.com

We will review the request and take appropriate action.

19. DATA SECURITY

We use reasonable administrative, organizational, and technical measures designed to protect information against unauthorized access, alteration, disclosure, loss, or misuse.

These may include authentication controls, access restrictions, secure service providers, and security controls provided by our technology infrastructure.

However, no website, mobile application, internet transmission, or electronic storage system can be guaranteed to be completely secure.

Users are responsible for maintaining the confidentiality of their account credentials and for notifying us if they suspect unauthorized account access.

20. DEVICE PERMISSIONS

Depending on the features you choose to use, Lukusa Elite may request device permissions such as:

camera access;
photo-library/media access; and
notification permission if notification functionality is made available.

Permission requests are intended to support the relevant feature.

You may manage device permissions through your device settings.

Declining a permission may prevent the corresponding feature from working but should not prevent access to unrelated functionality where technically feasible.

21. NOTIFICATIONS

Lukusa Elite may provide notification functionality where implemented and enabled.

If notifications are available, they will require the applicable device permission.

You can manage notification permissions through your device settings and any available in-app preferences.

We do not represent notification functionality as active where it has not yet been implemented.

22. COOKIES AND SIMILAR TECHNOLOGIES

We do not currently intentionally deploy advertising or behavioral-tracking cookies through dmlukusa.com.

However, our hosting platform and necessary website technologies may use cookies or similar technologies required for security, functionality, session management, or technical operation.

If we introduce analytics, advertising pixels, behavioral advertising, or other non-essential tracking technologies, we will update our disclosures and implement consent controls where required.

Third-party websites reached through external links, including Amazon, Payhip, and social-media platforms, may use their own cookies and tracking technologies. Their policies govern those technologies once you visit their services.