Privacy Notice

Who we are

The data user responsible for your information is Pristine Distributions (KL) Sdn Bhd, 46, Taman Berjaya, 10350 Georgetown, Penang, Malaysia. Privacy questions and data requests: [email protected].

1. What this notice covers

This notice explains how Luwy processes information when you create an account, practice, use simulations, use voice features, subscribe, or interact with social features. Luwy is for adults aged 18 and over.

2. Information we receive

• Account information: email address, authentication identifiers and account settings.
• Profile information: age, selected goals, contexts and training preferences. Age is used for age-appropriate safety controls.
• Practice information: scores, feedback, speech measurements, selected topics, skill progress and other information needed to provide the training service.
• Speech and voice: depending on the feature, your browser or a speech provider may process audio or speech-to-text. Luwy is designed not to retain raw audio after the feature's processing step unless a feature explicitly says otherwise.
• Payment information: subscription payment processing is handled by Stripe. Luwy does not need to store your full card number.
• Technical information: device, browser, security and diagnostic information needed to operate and protect the service.

3. AI processing

Luwy uses third-party AI and speech infrastructure to provide coaching, simulation, transcription, pronunciation or voice features. Depending on the feature, providers may include Anthropic, OpenAI and Microsoft Azure Speech. We send only the information needed for the requested operation and do not sell your practice data.

AI outputs are generated assistance, not certified language assessments, medical advice, employment decisions or psychological measurements.

4. What we keep

We keep account information and the performance information needed to show your history, progress, plans and entitlements. Luwy is designed to minimize retention of raw voice recordings and to avoid retaining full practice transcripts where they are not needed for the feature. Exact retention can vary by feature and operational requirement.

5. Age

Luwy is for adults aged 18 and over and is not directed to children. We do not knowingly collect personal data from anyone under 18. If you believe someone under 18 has created an account, contact us and we will delete it.

6. Social features

Friends and leaderboard features are designed to reveal limited profile and performance information rather than private practice content. Friends do not receive your transcripts or full practice history. You can control leaderboard visibility where the feature is available.

7. Security

We use authentication, access controls, rate limits and server-side protections appropriate to the service. No online service can guarantee absolute security. Do not put passwords, payment credentials or another person's sensitive information into practice prompts.

8. Your choices and data rights

Where applicable under Malaysian data protection law, you may have rights to be informed about processing, access and correct personal data, withdraw consent, object to certain processing or direct marketing, and request deletion where permitted. Luwy provides account export and deletion flows where available.

• You can update account information through supported account settings.
• You can stop optional marketing communications.
• You can cancel a subscription through the supported billing flow.
• You can request access, correction or deletion through the contact method provided by Luwy.

8A. Optional research sharing

If you choose to turn it on in Settings, we record coded patterns from your Simulate conversations (tone, communication moves, pressure level and how the other person's mood moved) under a pseudonymous code, never your words, voice, name or email. It is off by default, you can turn it off at any time and your rows are then deleted, and deleting your account deletes them too. Only aggregates with at least 20 contributing people are ever shared outside Luwy. Details: research data notice.

9. International processing

Some service providers may process information outside Malaysia. We use contractual and technical safeguards appropriate to the services we operate.

10. Changes

We may update this notice when the product, providers or legal requirements change. The version and date shown above identify the version presented on this page.